Cordes Finance Corporation - Page 8

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                In passing, we note the stipulation of the parties that                                  
                the ending deferred interest as calculated by respondent                                 
                in the amount of $3,091,395.88 should be increased by                                    
                $437,800.  We also note the stipulation that the earned                                  
                interest as calculated by respondent in the amount of                                    
                $3,084,170 should be increased by $295,200.  In this                                     
                opinion, we shall continue to refer to the amounts                                       
                originally calculated by respondent and used in the notice                               
                of deficiency in order to avoid confusion.                                               
                      Based upon the agent's analysis, respondent determined                             
                that petitioner's interest income had been understated in                                
                the amount of $3,084,179.12.  Respondent also determined                                 
                that petitioner's interest income had been understated by                                
                the difference between the aggregate deferred interest                                   
                computed from the ledger cards as shown above, $6,175,575,                               
                and the deferred interest shown on petitioner's books and                                
                records, $7,772,543, or $1,596,968.  Accordingly,                                        
                respondent determined that petitioner's interest income                                  
                had been understated in the aggregate amount of $4,681,147                               
                (i.e., $3,084,179 plus $1,596,968).                                                      
                      During the audit, respondent's agent asked Mr. Cordes                              
                to provide certain information pertaining to petitioner's                                
                bank deposits at Citizens Bank in Lawton, Oklahoma.                                      
                Mr. Cordes refused the agent's request.  Accordingly, the                                
                agent issued an administrative summons to obtain the                                     



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