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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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