- 41 -
which NDV was open for business was less than the amount of daily
gross receipts of NDV that Mr. Phielix had calculated for each
such day by using the Z reading difference in grand totals.
Throughout the period 1987 through 1990, more than 11,400 of
the approximately 140,000 transactions that were entered into the
cash register during that period did not appear on any of the
cash register tapes that Mr. Katerelos saved for those years.
The total of the various amounts entered into the cash register
for those missing transactions during the period that began on
January 1, 1987, and that ended on December 31, 1990, was approx-
imately $199,000.
Mr. Katerelos does not dispute that portions of the cash
register tapes are missing for the years 1987 through 1990 or
that transactions were entered into the cash register during
those years that do not appear on the cash register tapes that he
saved. In fact, Mr. Katerelos admitted that he discarded
(1) the portions of the cash register tapes that he did not
utilize to calculate the amounts of gross receipts that he
recorded in the gross receipts journals during the years 1987
through 1990 and (2) the guest checks. It is his position that
the missing transactions were nonsale transactions, such as
corrections for amounts treated as overrings or transactions
entered into the cash register for purposes of training employees
on its use, that did not generate gross receipts of NDV that he
failed to report in petitioners' returns for the years 1987
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