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$23,037.00 for November and December and I have included that on
my business income for 1994"; and (3) Dr. Kennedy's profit and
loss statement for October, 1994 (P & L statement), which shows
total year-to-date patient fees, as of October 31, 1994, of
$176,002.44. On the basis of these documents, respondent posits
that Dr. Kennedy's total reported 1994 gross receipts from patient
fees (earned before he became an employee of SWMG as of November
1, 1994) were understated by $3,760. Therefore, they must be
increased from $195,709 as reported to $199,469 as determined
after examination. The Kennedys offer no documentary rebuttal.
They merely state, on brief, that the adjustment is 9 years old,
the records are "impossible to trace", and it is "Dr. Kennedy's
recollection" that the $195,709 reported on his return "is the
accurate dollar amount that he received as gross sales for his
medical practice."
2. Discussion
Although the stipulated exhibits (in particular, the letter)
generally support respondent's determination, his numbers do not
quite add up. Whether the $176,002 representing Dr. Kennedy's
1994 gross receipts through October 31, 1994, is increased by
$23,797 (per the agent's report) or $23,037 (per the letter), the
result differs slightly from the total 1994 Schedule C gross
receipts of $199,469 respondent determined. On cross-examination
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