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Saturday "draw" number to obtain the "weekend differential".
Next, Agent Wilder multiplied the average daily "draw" number by
$10.95 (the daily and weekend rate), and then multiplied the
average Saturday "draw" figure, or weekend differential, by $7.95
(the weekend rate). These two figures were added together to
obtain the total gross receipts for that month. Agent Wilder
completed similar computations for each month for the years in
issue in order to estimate gross receipts for each year. Gross
receipts for each year were then reduced by 10 percent for
uncollectibles. The term "uncollectibles" refers to amounts that
could not be collected from subscribers for their newspaper
delivery service. The Star Telegram advised Agent Wilder that
the uncollectible rate ranged from a low of 5 percent to a high
of 10 percent, depending on the nature of the delivery route.
Agent Wilder's method of computing gross receipts did not
take into account awards or discounts offered by the Star
Telegram. Nor did it take into account the extra newspapers that
petitioner had after completing his deliveries. Furthermore,
because Agent Wilder did not have access to the ledger sheets,
she could not determine the actual numbers of subscribers to the
various subscription plans. Consequently, her computations only
take into account the two subscription plans to which
petitioner's customers most commonly subscribed.
Prior to the examination of petitioners' 1991 and 1992
returns, respondent's agents examined the returns of 200 to 300
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