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principally upon the biased testimony of Mr. Eddie
Crabtree. We find no credible evidence to support
petitioners’ argument that respondent’s determination is
wrong. In this regard, we accord no probative weight to
the testimony of petitioners’ witnesses.
As to petitioners’ final contention that respondent
failed to give them credit for the cover charges reported
on their returns for the years in issue, petitioners are
wrong. Respondent’s determination of the unreported income
of Crabtree Investments gives petitioners full credit for
the gross receipts or sales reported on each of the returns
in issue. Thus, any cover charges reported by petitioners
have been subtracted from the adjustment computed by
respondent for each of the subject years. Accordingly,
we find that petitioners have failed to prove that
respondent’s reconstruction of income from cover charges
is incorrect. See Rule 142(a).
Income From Food Sales
Petitioners argue that respondent’s estimate of food
sales is unreliable and arbitrary. Petitioners assert that
the revenue agent could have reviewed Crabtree Investments’
general ledgers to determine the actual amount of food
purchases because food was purchased by check. Petitioners
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