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tapes that he examined for periods outside the applicable period,
established the double-ups theory proposed by petitioner, and Mr.
Ozenne agreed--absolutely.
Mr. Chiate further inquired of Mr. Ozenne:
Q. Okay. So in addition to the actual dinner
checks for the period immediately after the fiscal year
(the applicable period) did you determine that that was
also true for the months immediately preceding the year
in question?
A. Yes.
Q. Okay. And did that support your opinion as to
the reasonableness of concluding that double-ups
account for the claimed deficiency of $120,000.
A. For the lion’s share of it. As I said
earlier, the gift certificates and the comps would have
accounted for a very small part of that. And I think
the real proof of that is Ms. Groom came out and
finished, I believe in May, the first part of May of
1995, and the questions that arose as to the accuracy
of her schedule.
Well, shortly after those questions arose, the
bookkeeper at the restaurant instituted a procedure
whereby they reconciled the total of the two adding
machine tapes to the daily tickets on a daily basis.
Now that was not available in our year under
audit, or prior, because no one thought it was
important. [Emphasis added.]
Testimony of Cecy Groom
Ms. Groom is a C.P.A. who has a bachelor’s degree in
business administration. She majored in accounting. At the time
of trial she was a business owner, managing and operating an
International House of Pancakes (IHOP) and was also an affiliate
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