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represents the total of four delayed savings deposits, also
detailed in the Findings of Fact above. The unexplained bank
deposits should be reduced by those amounts.
Both the corporate petitioner and the individual petitioners
argue that the proceeds of the rebate and coupon checks that were
cashed ended up in the corporate petitioner's bank deposits and
have been included by respondent in income twice. Other than
self-serving speculation, petitioners have not provided any
information as to the disposition of these cashed checks. Such
cash proceeds may have been part of the store deposits and
already excluded from the unexplained bank deposits. Since we
are unable to determine how much, if any, was deposited and
unable to distinguish such cash from the other items deposited,
we cannot find as fact that the proceeds of these cashed rebate
and coupon checks were included in the unexplained bank deposits.
However, there is evidence of the August 30, 1988, deposit of the
$502.44 check from Quinn within an unexplained deposit of $1,000
on that day, and the corporate petitioner's income should be
adjusted accordingly.
Additions to Tax under Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on the date prescribed (determined with regard to
any extension of time for filing), unless it is shown that such
failure is due to reasonable cause and not due to willful
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