Gabriel M. Daya, et al. - Page 11




                                        - 11 -                                        
               No. 4540719.                                                           
                    2 This amount includes check No. 265 in the                       
               amount of $596.83, which was not included in the                       
               “Schedule of Checks for 1996”, but which we infer                      
               from the record was payment on Bank of America                         
               Customline account.                                                    

          Petitioners have provided no additional information as to the               
          nature of these expenditures.                                               
               Gabriel’s checking account was maintained for personal                 
          expenditures.  He also made withdrawals from the account when               
          extra money was required to maintain the Foster City residence.             
          Deposits into the account in 1995 for which petitioners presented           
          records totaled $6,017.07, and disbursements for which records              
          were presented totaled $6,424.42.6  Gabriel identified several of           
          the deposits into the account in 1995 as his paychecks.  The                
          record provides no evidence as to the amount of any funds from              
          Gabriel’s checking account used to support his family in 1995.              
          Most of the disbursements from the account were in the form of              
          cash withdrawals.  The record provides no information regarding             
          Gabriel’s checking account in 1996.                                         
               Morhaf’s checking account primarily was used during 1995 to            
          pay his personal expenses.  He deposited no money directly into             
          the household checking account in 1995, but he gave money to his            



               6 Bank statements for Gabriel’s checking account were                  
          admitted into evidence for the following periods:  (1) Dec. 14,             
          1994, through Mar. 15, 1995; (2) May 13 through Aug. 15, 1995;              
          and (3) Sept. 14 through Dec. 12, 1995.                                     




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