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"Dennis Gandy Nursery" (account No. 21-5232-0). This latter
account was opened on December 29, 1988. Thereafter, this new
account was used as the business account for the nursery. All
references to the nursery bank account refer to the business bank
account in use as of the date discussed.
During the years in issue, the nursery had office procedures
that generally were followed by petitioners and nursery
employees. Various nursery office employees would assist the
walk-in customers and write up invoices. The chain store
invoices were generated from the computer. Petitioners continued
to maintain the two sets of ledgers. During 1985 through 1989,
petitioners maintained one set of ledgers to record receipts from
the nursery that generally were not deposited into the nursery
bank account. That set consisted of the ledgers that listed the
handwritten or typed invoices; those ledgers were referred to by
the nursery employees as the cash book or cash ledger or the
walk-in book or walk-in ledger (the walk-in ledger). Petitioners
maintained a second set of ledgers to record receipts from the
nursery that generally were deposited into the nursery bank
account. This second set of ledgers contained listings of the
computer-generated invoices; employees referred to these ledgers
as the deposits ledger or deposits book or the chain store book
or the chain store ledger (the chain store ledger).
During 1985 through 1989, the nursery sales invoices were
marked with a "P" when they were first posted to the appropriate
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