- 27 - reconciliations as reflecting the net effect to the corporate petitioner and thus a more accurate picture. On the contrary, Ms. Stroud's knowledge of these alleged loan transactions was limited, restricted by Mr. Sutton himself. The failure to document these transactions must weigh against petitioners. We have considered all deposits attributable to Mr. Sutton to the extent made possible by the record before us. The parties have stipulated that Mrs. Sutton loaned a total of $100,000 to the corporate petitioner during 1987; yet, we are unable to ascertain whether the last $10,000 installment was ever deposited in the corporate bank account. Similarly, Fred Sutton provided funds to the corporate petitioner. However, the Fred Sutton checks were included in the store deposits in part. The remaining Fred Sutton funds (the August 19, 1988 check for $10,000) were conceded by respondent. Therefore, the Fred Sutton funds do not assist in reducing the remaining unexplained bank deposits. However, the delayed deposits to the corporate petitioner's savings account for taxes, as described in the Findings of Fact above, do serve to account for unexplained deposits on March 16, 17, and 31, 1989. Also, respondent listed an unexplained deposit of $14,000 on July 27, 1988. For that date, the corporate petitioner's bank statement shows a withdrawal of $14,000 and a deposit in the amount of $14,118.12. The latter depositPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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