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We accord little weight to this testimony. Only Mr. Karcho
testified that the malfunctions of the token machines or the
manual release of tokens resulted in the meters recording the
insertion of cash when it did not occur; no other witness
corroborated this point. As for the use of business cash to
obtain tokens for private parties, the employee who corroborated
this practice worked at the arcade for no more than 4 months of
the 46 months5 covered by respondent’s income adjustments, and
the practice only occurred on those weekends when Mr. Karcho was
not present. We are satisfied in the circumstances of this case
that the Meter Readings Sheets are a reasonably accurate record
of Banner’s gross receipts for the years at issue, which is
sufficient to sustain the deficiency determination. Respondent’s
reconstruction of petitioners’ income need only be reasonable;
precision is not required. See Harbin v. Commissioner, supra;
Campise v. Commissioner, T.C. Memo. 1980-130.
The probability that the Meter Readings Sheets are
reasonably accurate is enhanced by other factors. The higher
gross receipts reflected on them provide a plausible explanation
of the source of the substantial cash that Mr. Karcho had at his
disposal during the years in issue. Mr. Karcho’s explanation for
5 No adjustments were made with respect to the last 2
months of Banner’s fiscal year ended Feb. 28, 1991, due to the
absence of Meter Readings Sheets covering that period.
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