Jerry L. Crabtree - Page 8




                                        - 8 -                                         

             obtained from Ms. Crabtree the original purchase orders for              
             beer and liquor purchases.                                               
                  All of Crabtree Investments’ original records that                  
             were provided to the revenue agent, other than the general               
             ledgers, were returned to petitioners and afterwards lost                
             in the fire that destroyed Justins in 1996.  They were not               
             available at trial.                                                      
                  Respondent’s determination of Crabtree Investments’                 
             unreported income for 1992, 1993, and 1994 is based upon                 
             eight different categories of income, as summarized in the               
             following schedule:                                                      
                                           1992         1993      1994                
             a.   Bar sales           $938,199  $397,502  $426,160                    
             b.   Package store sales      54,041    63,943    99,511                 
             c.   Cover charges            91,000    91,000    91,000                 
             d.   Vending machine receipts    7,954     6,944     6,714               
             e.   Food sales               6,500     6,500     6,500                  
             f.   Flower sales             2,314     1,220      -0-                   
             g.   Coke, juice & coffee     19,435    19,435    19,435                 
             h.   Pay telephone receipts      2,080     2,080     2,080               
                  Total               1,121,523   588,624   651,400                   
             Gross receipts or sales                                                  
             reported on return       479,829   263,151   229,508                     
             Adjustment                     641,694   325,473   421,892               












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