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"unreasonably large" and that aside from petitioner's testimony,
the record is devoid of any further evidence to support or
corroborate his assertions. To the contrary, we find that the
record is devoid of any evidence as to what constitutes an
"unreasonably large" glass of wine. Moreover, we find no reason
to doubt either the honesty or credibility of petitioner's
testimony concerning the size of wine drinks served at the
Bullfrog. Accordingly, we find that each wine drink sold
contained 6 ounces of wine. Consequently we conclude that
petitioner's gross receipts from the sale of wine are as follows:
Wine
Year Gross Receipts1
1987 $1,053.92
1988 1,499.80
1989 1,521.91
1990 1,503.49
1See Table IV in the attached appendix.
5. Liquor Sales
Petitioner asserts that each liquor drink sold contained 1.6
ounces of liquor and that respondent erred by calculating gross
receipts from the sale of liquor on the assumption that each
liquor drink sold contained only 1 ounce of liquor.
Respondent predicated the determination that each liquor
drink contained only 1 ounce of liquor on petitioner's earlier
statement to Revenue Agent Theresa Antoun (Ms. Antoun) during a
February 1990 interview. In that interview petitioner indicated
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