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masseuses their one-half of the credit card receipts in cash. We
disagree. First, petitioners have not shown that the volume of
credit card sales is significant. Petitioners contend that the
credit card receipts were up to 40 percent of their total
receipts. We disagree. Petitioners only accepted credit card
payments for about 1 year. There is no convincing evidence of
the total amount of petitioners' credit card receipts. The
unburned daily sheets show that the amount of credit card
receipts was for less than 16 percent of total Billings receipts
for 28 days in 1987, and there are no credit card receipts for
the Springfield daily sheets for 1987. Petitioners and
respondent agree that petitioners had considerably less income in
1987 than the other years in issue. Thus, we are not convinced
that the credit card volume was significant.
Second, petitioners contend that each credit card sale
reduced the amount of cash they received from the business
because petitioners paid the masseuse her share in cash. We
disagree. If a customer paid 2x dollars by credit card, and
petitioners paid 1x dollars in cash to the masseuse, petitioners
would receive all of the credit card payments. The fact that
petitioners did not split the credit card payment with the
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