Estate of Sylvia P. Goldman, Deceased, Marsha Goldberg and Linda Tanenbaum, Co-executrices - Page 8

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            $365,798.02 and understated funds in one account by $106,941.08.                          
            Inclusion of these items resulted in a $213,816.24 increase in                            
                  On September 19, 1994, petitioner filed its petition.  On                           
            May 9, 1995, petitioner and respondent executed a Stipulation of                          
            Settled Issues, in which petitioner conceded several of                                   
            respondent's determinations.                                                              
                  Petitioner, in its petition, disputed respondent's                                  
            disallowance of a $500 deduction for decedent's cleaning expenses                         
            and a $1,733 deduction for her rental expenses.  It also disputed                         
            respondent's determination that one of petitioner's bank accounts                         
            had a balance of $146,644.08 instead of $39,703.00, the amount                            
            that was reported on the estate's tax return.  Petitioner,                                
            however, offered no evidence at trial to refute these                                     
            determinations and failed to address these issues in its briefs.                          
            Accordingly, petitioner has not satisfied its burden of proof on                          
            these items, and respondent's determinations with respect to                              
            these issues are sustained.  Rule 149(b); Lowry Hosp. Assn. v.                            
            Commissioner, 66 T.C. 850, 851 (1976).  We now turn to the                                
            contested issues in this case.                                                            
            I.  Includability of the Sixteen $10,000 Checks                                           
                  We must first determine whether the value of the funds                              
            (i.e., $160,000), paid to recipients of sixteen $10,000 checks                            
            written by Marsha, is includable in the gross estate.  The gross                          

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