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1990 59,908.40
Mr. Sutton signed a personal financial statement for FCB
dated April 10, 1986, stating the Suttons' net worth as $588,600.
This statement indicates $18,000 in notes due from friends,
relatives, or affiliated companies. Mr. Sutton signed another
financial statement for FCB on May 23, 1987, stating the Suttons'
net worth as $844,000. This 1987 statement indicates $27,000 in
notes due from friends, relatives, or affiliated companies.
Neither financial statement lists any liabilities other than
notes payable to banks.
Federal Income Tax Returns
The Woolard & Hale firm prepared the tax returns of the
corporate petitioner and the Suttons for the years at issue. The
corporate petitioner's Federal income tax returns for taxable
years ending September 30, 1987, and September 30, 1988, were
due, under extension, and filed on the following dates:
Taxable Year Ending Due Filed
September 30, 1987 June 15, 1988 June 15, 1988
September 30, 1988 June 15, 1989 February 9, 1989
Respondent determined in the notice of deficiency to the
corporate petitioner that the extensions for those years were
invalid, since the balance due was materially understated.
The Suttons' Federal income tax returns for 1987 through
1990 were due, under extension, and filed on the following dates:
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