Nick Kikalos and Helen Kikalos - Page 4

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          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.                                          




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