- 40 - readings that Mr. Katerelos ignored in calculating the amounts of gross receipts of NDV that petitioners reported in their returns for those years, they also listed transactions that increased the grand total maintained by the cash register. By analyzing the cash register tapes that Mr. Katerelos saved for 1987 through 1990, respondent was able to ascertain the number of missing transactions that did not appear on any of the cash register tapes that Mr. Katerelos saved for those years and the Z reading differences in grand totals. Respondent determined that the amount of any such Z reading difference, less (1) the amount of gross receipts recorded by Mr. Katerelos in the gross receipts journals for a particular day and (2) any adjustments for amounts treated as overrings or shortages of cash for that particular day, constituted the amount of daily gross receipts of NDV that Mr. Katerelos was required to, but did not, report in petitioners' returns for each of the years 1987 through 1990.34 The amount of daily gross receipts of NDV that Mr. Katerelos had recorded in the gross receipts journals for a minimum of 650 of the 1,440 days throughout the period 1987 through 1990 on 34 The amounts that respondent determined constituted additional gross receipts of NDV that Mr. Katerelos did not report in petitioners' returns for 1987 through 1990 included sales tax that petitioners collected on sales by NDV. Petitioners do not argue that respondent's determinations of the amounts of their underpayments for those years should be reduced by the amounts of sales tax included in the unreported gross receipts determined by respondent, presumably because petitioners did not pay any sales tax that they collected on unreported transactions to the appro- priate local tax authorities.Page: Previous 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 Next
Last modified: May 25, 2011