Ralph E. Frahm & Erika C. Frahm - Page 6




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          $6,252.604 for Mr. Frahm’s Wellmark Plan C policy on the dates              
          indicated by a check drawn on, or electronic transfers from, an             
          individual checking account that she maintained (Ms. Frahm’s                
          individual checking account):                                               
                  Date of Payment                 Amount of Payment                   
                     06/22/2000                       $1,042.10                       
                     08/08/2000                       1,042.10                        
                     09/05/2000                       1,042.10                        
                     10/06/2000                       1,042.10                        
                     11/08/2000                       1,042.10                        
                     12/05/2000                       1,042.10                        
               During 2000, Ms. Frahm paid by an electronic transfer from             
          Ms. Frahm’s individual checking account premiums of $55.46 for a            
          health insurance policy issued in Ms. Frahm’s name by American              
          Association of Retired Persons (Ms. Frahm’s AARP policy).  During           
          that year, Ms. Frahm paid by a check drawn on Ms. Frahm’s indi-             
          vidual checking account premiums of $548 for a cancer insurance             
          policy issued in Ms. Frahm’s name by Conseco Health Insurance               
          Company (Ms. Frahm’s Conseco policy).                                       
               During 2000, in addition to the premiums that Ms. Frahm paid           
          for Mr. Frahm’s Wellmark Plan C policy, Ms. Frahm’s AARP policy,            
          and Ms. Frahm’s Conseco policy, Ms. Frahm paid a total of $3,325            


               4The parties stipulated that during 2000 Ms. Frahm paid to             
          Wellmark premiums totaling $6,254 for Mr. Frahm’s Wellmark Plan C           
          policy.  That stipulation is clearly contrary to the facts that             
          we have found are established by the record, and we shall disre-            
          gard it.  See Cal-Maine Foods, Inc. v. Commissioner, 93 T.C. 181,           
          195 (1989).  The record establishes, and we have found, that                
          during 2000 Ms. Frahm paid directly to Wellmark premiums totaling           
          $6,252.60 for Mr. Frahm’s Wellmark Plan C policy.                           





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