- 19 -
into a computer from which he produced a computerized summary
that displayed the same information as the handwritten summary
(first computerized summary).23
In addition to the first computerized summary, Mr. Phielix
created a second computerized summary (second computerized
summary) to display the amount of additional gross receipts of
NDV that he had calculated for each day during 1987 through 1990
on which NDV was open for business. Mr. Phielix used the infor-
mation in the first computerized summary to determine whether the
gross receipts of NDV were underreported in petitioners' returns
for 1987 through 1990. In that connection, Mr. Phielix treated
the amount of any Z reading difference in grand totals during the
years 1987 through 1990 as the amount of gross receipts of NDV
that petitioners were required to report for the last day of the
multiday period in respect of which Mr. Phielix had compared the
respective grand totals displayed on the cash register tapes that
Mr. Katerelos saved for those days. To illustrate, Mr. Phielix
treated the $1,498.11 Z reading difference in grand totals that
were shown on the respective January 4, 1987 and January 3, 1987
cash register tapes that Mr. Katerelos saved for those days as
22(...continued)
sec. 6663(a) for the penalty for fraud for any portion of the
underpayment for 1991.
23 Neither party advances any argument that our findings or
conclusions herein should be affected by any errors occurring
during the transfer into the computer of data by Mr. Phielix from
the cash register tapes that Mr. Katerelos saved.
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