- 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 1987Page: Previous 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 Next
Last modified: May 25, 2011