- 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 and
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: May 25, 2011