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estate taxes to the extent he has proven that he paid it with his
separate funds.
3. Tracing of Community Funds and Petitioner’s Separate
Funds
The parties agree that petitioner may use either the family
expenditure or direct tracing method to show the amount, if any,
of separate funds that he used to the pay community debts that he
seeks to deduct.
Under the family expenditure method, total community
expenditures are subtracted from total community funds to show
whether any community funds remain. Under the direct tracing
method, each check from and each deposit to a particular account
is listed in chronological order, and the balances in the account
are computed after each transaction. A separate transaction
account balance is computed for the community property, the
husband's separate property, and the wife's separate property for
each account.
4. Whether Exhibit 9 Is Admissible
Petitioner’s Exhibit 9 purports to use the direct tracing
method to show that he used his separate funds to pay the
community debts.3 Exhibit 9 is a worksheet consisting of eight
3 George Belyea, who represented petitioner in this case,
briefly testified to authenticate worksheets (including Exh. 9)
with which the parties had been working for several months to
trace petitioner’s community and separate funds. Respondent
objected to his testimony and the admission of the exhibits that
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