James E. and Chung H. Peacock - Page 30

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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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