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average monthly price of liquor purchased for 1992 is
approximately $146.13 per gallon.
Second, petitioners contend that respondent erred in
assuming that drinks contained 1 ounce of alcohol. The
revenue agent testified that petitioners told her at the
initial audit interview that all drinks contained 1 ounce
of liquor. At trial, Mr. Crabtree testified that he did
not recall making that statement to the revenue agent and
testified that a 3-ounce drink was common. In addition,
petitioners offered the testimony of three bartenders at
Justins to rebut the 1-ounce assumption. The first
bartender testified that drinks contained between 3 and 7
ounces of liquor. A second bartender testified that drink
size varied between 2 and 4 ounces. A third bartender,
who was not employed at Justins during the years in issue,
testified that she poured drinks containing between 2 and 3
ounces of liquor. On the basis of the entire record, we
find that respondent’s assumption that each drink contained
1 ounce of alcohol, which was based on petitioner’s
statement to the agent, is reasonable and that petitioners
have shown no reason for the Court to find otherwise.
Third, petitioners argue that respondent’s recon-
struction of bar sales does not take into account drink
specials offered by Justins during the years in issue.
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