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Spring Hill restaurant for the years at issue relating to, inter
alia, that restaurant's gross receipts consisted of sheets of
paper referred to by petitioners as sales sheets (sales sheets).
Mr. Mifsud prepared a sales sheet for each week day during those
years and made entries on each such sheet on each night of each
such week. Each sales sheet contained for each day of the week,
inter alia, a column headed "SALES". During the years at issue,
each night after Mr. Mifsud closed out the cash register at
Spring Hill restaurant, he filled in an amount under that column,
which purported to show that restaurant's total daily gross
receipts reflected on the cash register tape and guest checks for
each day. During the years at issue, each night after Mr. Mifsud
completed the sales sheet for the day, he discarded the cash
register tape and guest checks for that day. During those years,
each night after Mr. Mifsud closed out the cash register at
Spring Hill restaurant, he brought the cash receipts from that
day's restaurant operations to his house.
At all relevant times, Mr. Mifsud, who was knowledgeable
about Federal deposit insurance which insures U.S. deposits of
one person up to $100,000, and Ms. Mifsud maintained multiple
bank accounts. As of December 31, 1991, petitioners had
$220,872.67 on deposit at Barnett Bank, $160,000 of which was in
a certificate of deposit, $55,952.82 of which was in an individ-
ual retirement account, and $4,919.85 of which was in a checking
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