Haralampos Katerelos and Irene Katerelos - Page 41

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            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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