M.S. Food Stores, Inc. - Page 22

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                                        Number of                                     
                    Year      Amount Deposits                                         
                    1986      $63,008   51                                            
                    1987      83,403    52+                                           
                    1988      53,550    35+                                           
                    1989      60,541    25                                            
                    1990      62,650    57                                            
          Respondent also included the amounts of all rebate and coupon               
          checks issued to the corporate petitioner that were not accounted           
          for in the corporate petitioner's income.  Respondent since has             
          conceded amounts representing such rebate/coupon checks that were           
          shown to have been deposited in the corporate petitioner's bank             
          account.  Other adjustments are reflected in the concessions                
          listed below.                                                               
               Respondent has conceded (rounded to the nearest dollar) the            
          following:                                                                  
          Item                   1986  1987   1988   1989   1990                      
          Rebate/coupons        $3,593 $6,369 $20,935 $7,597 $18,054                  
          Annuity                               13,067*                               
          IRA Distribution                      14,337*                               
          Interest Income                       239*                                  
          Dividend Income                       140*                                  
          Tax on IRA                            1,434                                 
          Dependency Exemption 1,080    1,900   1,950                                 
               *Respondent concedes those items because the Suttons had               
          already conceded them during the audit, and those items should              
          not have been included in the notice of deficiency.                         
               The Suttons have conceded that they failed to report on                
          their individual income tax returns the following:                          
          Item                                1986      1987        1989              
          Dividend Income                     $180     $120        ---                





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