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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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