- 35 - checks cashed by the corporate petitioner, since we cannot distinguish checks that may have been handled in this fashion. We cannot find that the Suttons received any funds from Mr. Palmer. We have found that the Suttons received funds from the estate; yet, we are unable to trace such funds to the remaining unexplained bank deposits in the Suttons' personal bank account. In summary, petitioners have failed to prove that any of the Suttons' unexplained bank deposits derived from nontaxable sources. The individual petitioners argue that they should not have to include the proceeds of the cashed rebate and coupon checks in addition to the unexplained bank deposits, as this would be double counting. Since the disposition of the cash proceeds is unknown, we cannot find that they were part of the unexplained bank deposits. Additions to Tax under Section 6651 Respondent has determined additions to tax for late filing for the Suttons' taxable years 1987 through 1990. The Suttons applied for extensions in each of these years and, for years 1987 through 1989, filed their returns after the respective due dates as extended. They admit that the returns for 1987 through 1989 were filed after the due dates as extended, and if a deficiency should be found for any of these years, that some addition would apply for each of those years. However, they assert that thePage: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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