M.S. Food Stores, Inc. - Page 21

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          unexplained deposits do not include the store deposits.                     
               Respondent adjusted the corporate petitioner's income as               
          follows:                                                                    
                         Taxable Year Ending                                          
          Item           9/30/86   9/30/87   9/30/88   9/30/89   9/30/90              
          Purchase Rebates         $16,007   $24,308   $8,056    $20,561              
          Gross Receipts           41,039    180,913   41,220    73,608               
          Contributions            (1,320)   (1,247)   (843)     (728)                
          NOL Deduction  $35,851                                 5,909                
               Respondent has since conceded the amounts of those rebate              
          checks that were credited to the corporate petitioner's accounts            
          payable at the respective vendors, where net costs were used in             
          calculating cost of sales, and has conceded some receipts.  The             
          amounts of respondent's concessions are (rounded to the nearest             
          dollar):                                                                    
                                Taxable Year Ending                                   
          Item                  09-30-87   09-30-88   09-30-89    09-30-90            
          Rebates and coupons   $2,988     $1,625     $2,964      $5,050              
          Gross receipts        -0-        46,413     5,987       -0-                 
               The Suttons                                                            
               Mr. Board examined the Suttons' bank records and compiled a            
          list of specific unexplained deposits which respondent included             
          in the Suttons' income.  The yearly totals of these unexplained             
          deposits to the Suttons' personal bank accounts over the 5-year             
          period are:                                                                 










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