- 20 - this cash-–that he had a cash hoard saved since childhood-–is not credible.6 Also, petitioners concede on brief that Banner had unreported income. Finally, the nature of the Meter Readings Sheets themselves, the figures on which are detailed and meticulous, not rounded or repetitive, lend support to their authenticity. Petitioners’ next argument proceeds on the concession that Banner had unreported gross receipts from arcade game sales. Petitioners argue that even if Banner had gross receipts in excess of the amounts recorded on the Daily Income/Cash Receipts records and reported on Banner’s returns, the returns nonetheless accurately reflected taxable income because Banner paid expenses with unreported cash, such as for part-time workers, food and miscellaneous supplies, and game parts and repairs. Except in the case of part-time workers (discussed infra), petitioners’ claim of unreported expenses is supported only by vague testimony. They provided no basis on which any amount of such expenses might be estimated,7 let alone an amount equal to the 6 We note in this regard that Mr. Karcho purchased Banner in 1985 for $25,000 cash and a $25,000 note to the seller. If Mr. Karcho had a cash hoard predating his acquisition of Banner of the size that would account for his cash transactions during the years in issue, we wonder why he found it necessary to finance one-half of the acquisition price. 7 On brief, petitioners argue that a comparison of the deductions taken on the last tax return filed by Banner under its (continued...)Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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