- 37 -
Accordingly, we find that each liquor drink sold contained 1.3
ounces of liquor. Consequently we conclude that petitioner's
gross receipts from the sale of liquor are as follows:
Liquor
Year Gross Receipts1
1987 $28,856.38
1988 42,755.46
1989 52,185.19
1990 28,551.23
1See Table V in the attached appendix.
6. Conclusion
On the basis of our findings above, we conclude that
petitioner had unreported gross receipts of $104,917.40 for 1987,
$116,072.49 for 1988, $127,473.82 for 1989, and $31,369.34 for
1990.36
B. Expenses
1. Band Expenses
Petitioner argues that he is entitled to deductions for band
expenses he incurred during the years in issue. Respondent
allowed petitioner a deduction for band advertising expenses but
allowed no deduction for the related band expenses on the ground
that petitioner failed to substantiate those expenses.
The Court must estimate the amount of the deductible expense
35(...continued)
Respondent conceded on brief that 16 percent is the proper
discretionary use allowance for liquor sales.
36 See Table VI in the attached appendix.
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