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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-
tion.
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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