- 38 -
NDV's gross receipts were only $323,037.31
Turning now to respondent's analyses of the cash register
tapes that Mr. Katerelos saved for the years 1987 through 1990,
Mr. Katerelos saved one cash register tape for each day through-
out those years on which NDV was open for business. Those cash
register tapes contained detailed information concerning certain
transactions entered into the cash register, including (1) a
nonresettable, consecutive transaction number for each transac-
tion, (2) the transaction total of each transaction, (3) the date
of each transaction, and (4) for certain periods during the years
at issue, the time of each transaction. In addition, a Z reading
on each cash register tape that Mr. Katerelos saved for the years
at issue showed a summary of all the transactions entered into
the cash register since the last Z reading, including the total
sales since the last Z reading and the amount of the non-
resettable grand total as of the time of the Z reading.32
31 The $21,094 that petitioners reported as gross income in
their return for 1987 plus the additional gross receipts of NDV
of $40,111 that respondent determined, and that we sustain below,
that petitioners failed to report for that year equals approxi-
mately $60,000 in gross income for 1987. The $323,509 that
petitioners reported as gross receipts of NDV in their return for
1987 plus the additional gross receipts of NDV of $40,111 that
respondent determined, and that we sustain below, that petition-
ers failed to report for that year equals approximately $360,000
of gross receipts for 1987. On the record before us, we believe
that, when petitioners believed it was to their advantage, they
admitted having additional gross income and/or additional gross
receipts of NDV in almost the exact amount determined by respon-
dent for 1987.
32 Activation of the Z or reset mode also caused the cash regis-
(continued...)
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