Haralampos Katerelos and Irene Katerelos - Page 14

                                                 - 14 -                                                   

            having generated the first Z reading on such a tape, Mr.                                      
            Katerelos correctly reentered all the transactions that had thus                              
            far occurred for the day15 and entered additional transactions as                             
            they occurred during that day.  Thereafter, on that same day, Mr.                             
            Katerelos activated the Z mode a second time to generate the                                  
            second Z reading on the cash register tape that he saved for the                              
            day.  Mr. Katerelos recorded in the gross receipts journals the                               
            total sales from the second Z reading for the day as the amount                               
            of NDV's gross receipts for that day.16                                                       
                  During the years at issue, Irwin Berlat (Mr. Berlat),                                   
            petitioners' accountant,17 used the daily amount of gross re-                                 
            ceipts of NDV that Mr. Katerelos had recorded in the gross                                    
            receipts journals for those years in order to calculate the                                   
            amounts of NDV's monthly18 and annual gross receipts for those                                
            years.  In addition to giving Mr. Berlat the gross receipts                                   

            15  It usually took Mr. Katerelos five to ten, and not more than                              
            30 minutes, to reenter those transactions.                                                    
            16  Mr. Katerelos treated the total sales from the first Z read-                              
            ing as if it had been an overring (even if it was not) in that he                             
            did not include it in the amount of NDV's gross receipts that he                              
            recorded for that day in the gross receipts journal.                                          
            17  Mr. Katerelos employed Mr. Berlat as the accountant for NDV                               
            when Mr. Berlat's father, who had been performing that function,                              
            died.  Although it is unclear from the record when Mr. Berlat's                               
            father died, it appears that he may have passed away during 1987.                             
            18  Following the close of each month during each of the years at                             
            issue, Mr. Berlat visited the premises of NDV, obtained the gross                             
            receipts journal from Mr. Katerelos, and calculated from that                                 
            journal the amount of NDV's gross receipts for the month just                                 

Page:  Previous  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  Next

Last modified: May 25, 2011