- 14 - OPINION Deficiency The record in this case amply demonstrates that petitioners maintained two sets of books with respect to the operations of Banner. One set, provided to their accountant each year for purposes of preparing Banner’s Federal income tax returns, recorded gross receipts as an amount equal to the deposits made to Banner’s corporate bank account. These records also purported to provide a breakdown of the daily bank deposit figure into categories by source of income (e.g., “Arcade Game Income”, “Food & Pop Sales”) which, at least in the case of the “Food & Pop Sales”, petitioners have conceded substantially understated gross receipts.3 The other set of records, which came to light as a 2(...continued) game income with respect to those months in 1991. In addition, there were no records with respect to food sales for Banner’s 1991 taxable year, and as a result respondent did not determine any unreported income with respect to food sales for that year. The parties have reached agreement with respect to the amount of gross receipts, as well as additional costs of goods sold, attributable to Banner’s food sales in 1987, 1988, 1989, and 1990. See supra note 1. Accordingly, the unreported income that remains in dispute concerns arcade game receipts only. 3 The record in this case contains the “Daily Income Records”, which treat a day’s bank deposit amount as that day’s gross receipts, covering all of the years in issue except 1991. The “Cash Receipts” records in evidence, which purport to break down the bank deposit amount into components such as arcade game and food sales, cover all years except 1990 and 1991. However, petitioners have stipulated that they provided similar records to their accountant for each year at issue for purposes of preparing (continued...)Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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