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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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