Manuel and Margaret Karcho - Page 23




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          agree with respondent that for 1987 and 1988, no such adjustment            
          would be reasonable, because Banner deducted amounts for wages in           
          those years and the record does not indicate whether these                  
          amounts were paid by cash or check.  With respect to 1991, we do            
          not believe any offset is appropriate because the reconstruction            
          of gross receipts for that year is obviously incomplete.  That              
          is, there were no Meter Readings Sheets for the last 2 months of            
          fiscal year 1991 and no food sales records for the entire year;             
          as a consequence, respondent did not determine any additional               
          gross receipts from those sources for those periods.                        
               Accordingly, we sustain respondent’s determination that                
          petitioners had unreported income from Banner of $143,552 for               
          1987, $149,458 for 1988, and $21,603 for 1991.  We further hold             
          that petitioners had unreported income from Banner of $131,686              
          for 1989 (i.e., respondent’s reconstruction of $160,600 less an             
          offset of $28,914 for wages paid with unreported cash) and                  
          $109,566 for 1990 (i.e., respondent’s reconstruction of $137,976            
          less an offset of $28,410 for wages paid with unreported cash).             







               9(...continued)                                                        
          Sheets for Banner’s fiscal year ended Feb. 28, 1990, in the                 
          record.                                                                     





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