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deposits. On the whole, that has not been established.
The totals of the personal checks Mr. Sutton wrote to or on
behalf of the corporate petitioner are summarized in the Findings
of Fact above. However, most of the personal checks that were
deposited were part of the store deposits and, thus, do not
reduce the corporate petitioner's unexplained bank deposits.
Those checks that were deposited separately from the store
deposits and that do not constitute income to the corporate
petitioner are listed separately in the Findings of Fact above.
As for the proceeds of personal checks that were cashed, Mr.
Sutton could not remember their specific disposition and, thus,
could not correlate their proceeds to the unexplained bank
deposits. Checks written to third parties do not explain bank
deposits. There is no credible evidence of any cash
contributions from Mr. Sutton to the corporate petitioner, either
from any of his personal funds or from any funds deriving from
Mr. Palmer.
Both the corporate petitioner and the individual petitioners
allege that Mr. Sutton loaned small amounts to the corporate
petitioner regularly and withdrew small amounts regularly, in
essence, alleging that the same funds were loaned and repaid over
and over. They argue that respondent has distorted the corporate
petitioner's income by summing the amounts advanced without
subtracting the repayments. Petitioners point to Ms. Stroud's
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