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deposited in the corporate petitioner's bank account were part of
the store deposits; i.e., those deposits into the corporate
petitioner's checking acount that were recorded as deposits on
the green sheets. Accordingly, those amounts are not part of the
unexplained bank deposits of the corporate petitioner. Among the
checks included above, those checks relating to deposits other
than the store deposits include the following:3
Date Check Number Amount
05-19-89 0109 $3,000
11-24-89 0195 3,000
12-01-89 0203 4,000
12-21-89 10,000
12-29-89 20,000
As to his personal checks to the corporate petitioner that were
cashed, Mr. Sutton did not know the specific disposition of the
proceeds of those personal checks.
Fred Sutton also wrote checks to the corporate petitioner
which, during the years before the Court, included the following.
Date Amount
08-19-88 $10,000
04-21-90 500
09-20-90 11,000
On August 19, 1988, the corporate petitioner made a deposit of
$10,000 to its bank account in addition to the store deposit for
that date. We cannot determine that the other two checks from
3 We have not included those checks where it is clear that
respondent either did not include the related deposits in the
unexplained deposits or has conceded them.
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