- 25 - 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. PetitionersPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
Last modified: May 25, 2011