-27-
formula to the receipts shown on the four daily sheets in
evidence produces the following results:
Joplin Springfield Springfield Billings
Nov. 1983 Nov. 1983 Apr. 1987 Apr. 1987
Total receipts $42,696 $39,030 $50,306 $25,700
Petitioners' share 21,348 19,51525,153 12,850
Multiplied by 3/7 9,149 8,363 10,780 5,507
Reported amounts 8,944 8,124 10,779 5,189
Difference $205 $239 $1 $318
Thus, petitioners told their bookkeeper about 3/7 of their one-
half share of the gross receipts shown on these four daily
sheets.
Petitioners contend that there is no proof that they used
the skim formula in other months. We disagree. K.C. Urbon
testified that petitioner-husband instructed her to use it and
that she did for 3 months in 1987.
Respondent did not determine petitioners' sauna income by
applying the 3/7 formula. However, the application of the skim
formula to the 4 months for which daily sheets exist shows that
respondent's determination is reasonable.
3. Petitioners' Tokyo Sauna Income
Petitioners argue that respondent's determination of the
amount of petitioners' income from the Tokyo Saunas for 1983 is
too large compared to the other years in issue because there is
no evidence that the two Tokyo Saunas petitioners owned in 1983
had greater total earning capacity than the three they owned in
1984 and 1985. We agree with petitioners in part.
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