- 35 - 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 hadPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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