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Bar Sales
Petitioners attack respondent’s reconstruction of bar
sales on four grounds. First, petitioners assert that
the revenue agent purportedly used the purchase
records provided by Jerry Crabtree. However, the
volume of alcohol used by the revenue agent in
her analysis of reconstructing bar sales is
inconsistent with the volume of alcohol actually
purchased by the corporate taxpayer.
Petitioners argue that the revenue agent should have used
the DABT Summary of Purchases as the starting point to
reconstruct gross receipts from alcohol sales.
Petitioners claim that the DABT Summary of Purchases
shows that Justins purchased 67,712 ounces of liquor (not
including wine or beer) during 1992. Using petitioners’
purchase orders, on the other hand, the revenue agent
determined that Justins purchased 391,294.82 ounces of
liquor during 1992. Petitioners assert that respondent’s
use of Crabtree Investments’ purchase orders rather than
the DABT Summary of Purchases results in an overstatement
of 323,582.82 ounces in liquor purchases. Petitioners do
not reconcile this difference or explain why their purchase
records reflect purchases that are so much greater than
those reflected in the DABT Summary of Purchases.
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