Haralampos Katerelos and Irene Katerelos - Page 17

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            ceipts of NDV for that day that he recorded in the gross receipts                             
            journal for 1987, was only $689.48.  The difference between the                               
            respective grand totals for those two days (viz., $1,498.11)                                  
            exceeded the total sales according to the Z reading on the cash                               
            register tape that Mr. Katerelos saved for January 4, 1987 (viz.,                             
            $689.48) by $808.63.  Such $808.63 excess was the total of the                                
            various amounts entered into the cash register for the 79 missing                             
            transactions between January 3, 1987, and January 4, 1987.                                    
                  Respondent's Audit                                                                      
                  During the summer of 1990, respondent's revenue agent, James                            
            Phielix (Mr. Phielix), conducted an audit of petitioners' returns                             
            for 1987, 1988, and 1989.  Mr. Phielix' examination of their 1990                             
            and 1991 returns did not commence until early 1993 because of an                              
            ongoing criminal tax investigation of Mr. Katerelos that ended                                
            when Mr. Katerelos was informed by correspondence dated December                              
            15, 1992, that he was no longer the subject of such an investiga-                             
                  During the course of his examination of petitioners' returns                            
            for the years at issue, Mr. Phielix created a handwritten summary                             
            that showed for each day during the years at issue the following                              
            data or information displayed on the cash register tape that Mr.                              
            Katerelos saved for each day during those years:  The date, the                               
            total sales according to the Z reading, the first and last                                    
            transaction numbers, the number of missing transaction numbers                                
            between the first transaction number on the cash register for                                 

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