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of their unexplained bank deposits in addition to those conceded
by respondent as follows:
Item 1990 1991
Insurance reimbursements,
contributions from relatives
for Nicholas $2,500 $2,500
Other gifts from relatives 500 500
Reimbursements--parents 500 1,000
Reimbursements--check writing 1,000 1,000
Total reductions $4,500 $5,000
Although Scott testified that he made one or two trips to
Japan in 1990 and one in 1991, bringing back money both times, we
do not allow any additional amounts based on that testimony. It
is too vague for us to make findings regarding the dates and
amounts. Neither do we allow anything in 1991 for repayment of a
loan to Motomi's brother, Junichi. Although there is evidence
that a loan was made in that year, the record is silent as to
when, if ever, or in what amounts or form, Junichi repaid it.
With regard to the remaining unexplained bank deposits, we
sustain respondent.
We turn now to the penalties for 1990 and 1991 under section
6662(a).
Section 6662(a)
Respondent determined that the Kudos are liable for
accuracy-related penalties for negligence under section 6662(a)
for 1990 and 1991. Petitioners contend that the Kudos were not
negligent, because they relied in good faith on Nakamura to
prepare their tax returns properly for those years. Respondent
contends that petitioners failed to prove that the Kudos had
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