Ralph E. Frahm & Erika C. Frahm - Page 11




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          the dates indicated by electronic transfers from Ms. Frahm’s                
          individual checking account:                                                
                  Date of Payment                 Amount of Payment                   
                     01/05/2001                       $1,117.60                       
                     02/05/2001                       1,117.60                        
                     03/05/2001                       366.80                          
                     04/05/2001                       742.20                          
                     05/07/2001                       742.20                          
                     06/05/2001                       742.20                          
                     07/05/2001                       742.20                          
                     08/06/2001                       742.20                          
                     09/05/2001                       742.20                          
                     10/05/2001                       742.20                          
                     11/05/2001                       742.20                          
                     12/05/2001                       742.20                          
               During 2001, Ms. Frahm paid by a check drawn on her individ-           
          ual checking account premiums of $548 for Ms. Frahm’s Conseco               
          policy.                                                                     
               During 2001, Mr. Frahm, as Ms. Frahm’s employer, paid by               
          checks drawn on the business checking account premiums of $575.96           
          for a long-term care insurance policy issued in Ms. Frahm’s name            
          by American Fidelity Assurance Company (Ms. Frahm’s long-term               
          care policy).  During that year, Mr. Frahm, as Ms. Frahm’s                  
          employer, also paid by a check drawn on the business checking               


               11(...continued)                                                       
          to the facts that we have found are established by the record,              
          and we shall disregard it.  See Cal-Maine Foods, Inc. v. Commis-            
          sioner, 93 T.C. at 195.  The record establishes, and we have                
          found, that during 2001 Ms. Frahm paid directly to Wellmark                 
          premiums totaling $9,281.80 for Mr. Frahm’s Wellmark Secure Blue            
          Select policy.                                                              





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