- 23 - 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.Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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