M.S. Food Stores, Inc. - Page 8

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          corporate petitioner's books as rebates.                                    
               Many of these coupon and rebate checks were deposited into             
          the corporate petitioner's bank account.  A coupon check issued             
          by Quinn on August 26, 1988, in the amount of $502.44, was                  
          deposited in the corporate petitioner's bank account on August              
          30, 1988, along with $500 in currency; change of $2.44 was                  
          returned.  That amount of $502.44 was not included in the notice            
          of deficiency as part of the corporate petitioner's unreported              
          rebate amounts because it had been reported on the corporate                
          petitioner's tax return.  However, respondent included this                 
          $502.44 as part of an unexplained corporate bank deposit made on            
          August 30, 1988.                                                            
               The following chart sets out the source, amounts, and                  
          disposition of the various rebate and coupon checks included in             
          the deficiency notice to the corporate petitioner:                          
                           Rebate/Coupon Checks:  the Corporate Petitioner            
                                       Amount Credited  Amount Deposited              
                           Amount in   on Vendor's Accountin Corporate Bank  Amount     
          TYE   Vendor     Deficiency Notice (Conceded by Respondent)      Account      Cashed
          9-30-87 Quinn    $11,420.62  -0-              $4,316.44   $7,104.18         
                Coke       4,138.00    $2,988.00        1,150.00    -0-               
                Carolina Dairies        447.72-0-           132.48    315.24           
                Total:     $16,006.34  $2,988.00        $5,598.92   $7,419.42         
          9-30-88 Quinn    $10,647.07  -0-              $4,413.88   $6,233.19         
                Coke       11,083.75   $1,625.00        9,458.75    -0-               
                Carolina Dairies      1,757.86-0-              1,757.86    -0-               
                Philip Morris 819.00         -0-           819.00    -0-              
                Total:     $24,307.68  $1,625.00        $16,449.49  $6,233.19         
          9-30-89 Quinn    $2,195.21   $1,338.69        $502.39     $354.13           
                Coke       5,190.00    1,625.00         3,565.00    -0-               
                Carolina Dairies        298.92-0-              298.92      -0-               
                Philip Morris  372.00        -0-           372.00     -0-             
                Total:     $8,056.13   $2,963.69        $4,738.31   $354.13           
          9-30-90 Coke     $10,392.50  $5,045.00        $5,347.50   -0-               
                Philip Morris1,080.00    -0-              1,080.00    -0-               
                Nash Finch    9,088.75       4.92         8,334.64  $749.19           
                Total:     $20,561.25  $5,049.92        $14,762.14  $749.19           




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