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journals that Mr. Katerelos maintained for the years at issue,
Mr. Katerelos provided him with the daily cash register tapes
that he had saved for those years and that he had used to arrive
at the amounts of daily gross receipts he recorded in those
journals. Mr. Berlat used those gross receipts journals to
prepare petitioners' returns for the years 1987 through 1989, and
another accountant, Don Bailey (Mr. Bailey), used those journals
to prepare their returns for 1990 and 1991.
For certain days during the years at issue, there is a gap
between the last transaction number shown on the cash register
tape that Mr. Katerelos saved for a particular day and the first
transaction number shown on the cash register tape that he saved
for the next day. Neither those missing transaction numbers nor
the transactions to which the cash register assigned those
numbers appear on any of the cash register tapes that Mr.
Katerelos saved for the years at issue. (We shall sometimes
refer (1) to the transactions that were entered into the cash
register during the years at issue but that do not appear on any
of the cash register tapes Mr. Katerelos saved for those years as
the missing transactions and (2) to the transaction numbers
assigned to those missing transactions as the missing transaction
numbers.) The missing transactions included transactions that
increased the grand total maintained by the cash register.19
19 The missing transactions and the missing transaction numbers
(continued...)
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