Theodore Langworthy, Jr. - Page 6

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          purchases (unreported gross receipts), and petitioner kept no               
          records of the unreported gross receipts.  At the time petitioner           
          filed his returns for the years in issue, he knew that the                  
          unreported purchases and the unreported gross receipts were not             
          reported on his return.                                                     
               Mr. Dillon, of Acme Tax Service, prepared petitioner's                 
          returns for the years in issue solely from the information                  
          provided by petitioner, which included cash register receipts,              
          check stubs, cash payouts, a payroll book, a weekly rental book,            
          and bank statements.                                                        
          Unreported Gross Receipts                                                   
               Using the beer, wine, and liquor purchases indicated on the            
          vendor invoices, the drink prices charged by petitioner for sales           
          of those beverages, and allowing an adjustment for discretionary            
          use (i.e., breakage, spillage, and complimentary drinks),                   
          respondent reconstructed petitioner's total gross receipts.  From           
          total gross receipts respondent subtracted reported gross                   
          receipts to arrive at the amount of petitioner's unreported gross           
          receipts.                                                                   
          1.   Purchases                                                              
               Vendor invoices indicate the following purchases:6                     


          6    During 1988, 1989, and 1990, petitioner purchased Bartyles             
          and James brand wine coolers.  Respondent did not include the               
                                                             (continued...)           






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