Austin B. Ewell, Jr. - Page 22

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          identified the source of the $1,496.69 or any of the beginning              
          balances in Exhibit 9.  Exhibit 9 does not show that they spent             
          more than $67,611 by April 1, 1987.  Exhibit 9 does not properly            
          apply the direct tracing method.  It does not directly trace                
          petitioner’s separate funds through the commingled accounts to              
          the specific payments that he seeks to deduct.  Exhibit 9 does              
          not list the balance of each account and the balance of                     
          petitioner’s separate funds computed after each transaction as              
          required by the direct tracing method.  It appears that Belyea              
          combined petitioner’s five accounts on Exhibit 9.  Exhibit 9 does           
          not directly trace each transaction in each account and show the            
          community and separate fund balance after each transaction.                 
          Thus, even if Exhibit 9 were fully admitted, petitioner has not             
          proven that the community funds were in deficit after April 1,              
          1987.                                                                       
               We conclude that petitioner has not shown that he used his             
          separate funds to pay his former spouse’s share of mortgage                 
          interest and property taxes for their business properties through           
          the direct tracing method.                                                  
                    b.   Family Expenditure Method                                    
               Respondent concedes that the family expenditure method shows           
          that petitioner used some of his separate funds to pay mortgage             
          interest and property taxes.  Respondent concedes that petitioner           







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