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Crabtree Investments state as follows: “Food income was
determined using $125 per week based on Florida Department
of Revenue estimates for a business your size.” Respondent
used this estimate because Crabtree Investments did not
provide any purchase records for the food sold in the bar.
Income From Cola, Juice, and Coffee Sales
Respondent determined that sales of nonalcoholic
beverages, such as cola, juice, and coffee, were $19,435
per year for each of the years at issue. The notices of
deficiency issued to Crabtree Investments provide the
following explanation:
Coke, Juice and Coffee sales were determined
using an assumption that one quarter of the
persons paying cover charges for nights when
entertainment was provided [Thursday, Friday,
and Saturday] would pay $1.50 for these items.
Income From Pay Telephone Receipts
Respondent determined pay telephone receipts to be $40
per week or $2,080 per year for each of the years in issue.
The notices of deficiency issued to Crabtree Investments
provide the following explanation: “Pay telephone income
was determined using $40 per week based on Florida
Department of Revenue estimates for a business your size.”
The revenue agent used this estimate because petitioners
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