M.S. Food Stores, Inc. - Page 24

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          petitioner's income should be increased by the amounts of those             
          coupon checks not previously recorded in the corporate                      
          petitioner's books as rebates.  The corporate petitioner argues             
          that the value of the coupons was included in income as a                   
          component of gross receipts and, therefore, should not be                   
          included again upon receipt of the coupon checks.  The corporate            
          petitioner has failed to establish the factual predicate for its            
          argument.  We cannot find that the coupon amounts were initially            
          included in the gross receipts ("register") figures on the green            
          sheets.                                                                     
               No cash register tapes or reconciliation records were                  
          submitted.  The amount of income received from coupons was not              
          accounted for as a separate item on the corporate petitioner's              
          green sheets or any other books or records.  Accounting practices           
          were inconsistent, some coupon checks being recorded as rebates             
          on the green sheets.  Ms. Stroud from the accounting firm knew              
          nothing of the accounting procedures for coupons or coupon                  
          checks.  The corporate petitioner has not met its burden of                 
          showing respondent's determination to be incorrect.  Therefore,             
          we sustain respondent's determination, as adjusted by                       
          respondent's concessions, which are detailed in the Findings of             
          Fact above.                                                                 
               Unexplained Bank Deposits                                              
               Every person liable for tax is required to keep books and              






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