Haralampos Katerelos and Irene Katerelos - Page 38

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            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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