- 24 - 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 andPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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