Shigenori Kudo and Motomi Kudo, et al. - Page 35

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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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