M.S. Food Stores, Inc. - Page 27

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          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 deposit                    






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