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reconstruction shows that only $7,762 of receipts from “United
Yacht Charters” was included therein for 1994. We therefore
conclude that the downward adjustment to respondent’s figure that
is appropriate in light of petitioner’s refund evidence is capped
at $7,762. The remaining two checks, both evidencing refunds to
“K.D.B.” aggregating $8,900, should result in a downward
adjustment in that amount, as respondent’s reconstruction for
1994 includes receipts from “K.D.B.” in excess of $8,900. Thus,
we conclude that petitioner has shown error in respondent’s
reconstruction of 1994 gross receipts; they are overstated by
$16,662.
For 1996, all but 3 of petitioner’s 12 proffered checks
suffer the defect of their payee’s not having been shown to be a
source of a deposit in respondent’s reconstruction of
petitioner’s charter gross receipts; that is, none of the payees
on these purported refund checks is listed as the source of a
deposit in respondent’s reconstruction of 1994, 1995, or 1996
gross receipts, and petitioner has not established that any was a
source in some other year. Of the three remaining, we disregard
two because the checks (for $1,020 to “Betty Corson Yacht
Charter, Inc.” and for $2,000 to “Gold Coast”) do not on their
face indicate that they are refunds, and there is no other
evidence to corroborate petitioner’s claim to that effect. The
remaining check, evidencing a refund of $2,000 to “Al Schrold”,
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