- 4 - respect to 1996 sales activity, and some buy-down checks received in 1998 contained payments with respect to 1997 sales activity. Nick’s Liquors also accepted or honored paper coupons presented by customers. Petitioner submitted the coupons to each cigarette manufacturer for reimbursement of the face value of the coupon, plus postage costs. Petitioner reported $653,164 in coupon and buy-down income on his 1997 Federal income tax return. During the audit examination, petitioner provided respondent with four worksheets5 detailing coupon and buy-down and rack and promotional income. Each worksheet included summary totals for all four stores. One worksheet reflected coupon and buy-down income totaling $777,848, while the remaining worksheets reflected a total of $521,695. To protect the Government’s interest, the revenue agent based her examination on the worksheet that reflected $777,848 of coupon and buy-down income. Despite requests by the revenue agent, petitioner did not furnish respondent with adequate records to substantiate the amount of coupon and buy-down income recorded by each store on a daily, monthly, or annual basis. 5 The record is unclear as to why petitioner provided four separate summary worksheets to the revenue agent. Petitioner did not adequately explain why they were substantially similar with one inconsistency as to the total.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011