- 15 - together with a reconciliation of the register 2 tape prepared by Mr. Kelson. The reconciliation of the register 2 tape showed that Mr. Kelson determined that the gross sales reported on the register 2 bar tape was $1,580.90. He then determined that the Code V (5) transactions recorded on the tape totaled $628.65. Code V transactions are the bar sales recorded on the register 2 tape that are carried over onto the register 1 tape in the dining area. Mr. Kelson deducted the $628.65 from gross sales of $1,580.90, leaving a balance of $952.25. This step in Mr. Kelson’s reconciliation process eliminated any double-ups between the dining room and bar area tapes. Mr. Kelson then deducted “comps” of $12 and overrings of $14, resulting in net sales of $926.25, the amount entered by Ms. Groom as the net sales recorded on register 2. This procedure was followed by Ms. Groom during her entire audit of petitioner’s taxable year ended May 31, 1995. Petitioner contends that it carefully maintained adequate books and records for several years to determine its income. The only records the petitioner was unable to produce for examination are the records for the applicable period. Petitioner, through Messrs. Chiate and Ozenne, then fabricated a scenario orchestrated to prove that the determined unreported income of $120,371 can be explained away by showing that the entries on thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011