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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 the
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