Janice L. Morris - Page 16

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          paid Mr. Morris during 1987.  The category "Miscellaneous" for              
          1987 also reflected a $6,263.50 disbursement to Bill Abbott on              
          May 12, 1987.  That disbursement was the downpayment that peti-             
          tioner made to purchase a 1987 Sunbird, which was the only car              
          available to her at that time.  Petitioner borrowed the balance             
          of the purchase price for that car.                                         
               The disbursements that petitioner made during the years at             
          issue were not lavish in comparison to the disbursements that she           
          made during years prior to the years at issue.                              
               Other Deposits, Disbursements, and Transfers                           
               In addition to the deposits into the joint checking account            
          that were reflected in petitioner's deposits analyses, certain              
          deposits were also made to the joint savings account.  The total            
          amounts deposited into that account during 1987, 1988, and 1989             
          were $5,015.82, $16,865.45, and $3,432.41, respectively.                    
               During 1988, Mr. Morris wrote (1) two checks totaling                  
          $17,011 on the Trust 768 account to pay the joint Federal income            
          tax liabilities that petitioner and he owed for 1986 and 1988 and           
          (2) three checks totaling $2,853.72 on the Trust 768 account to             
          pay the joint income tax liabilities that petitioner and he owed            
          the State of Illinois for 1986 and 1988.17                                  

          17  The joint Federal and State income tax liabilities for 1986             
          that Mr. Morris paid during 1988 were attributable to the in-               
          crease in taxes shown in an amended joint return that petitioner            
          and Mr. Morris filed for 1986, and the joint Federal and State              
          income tax liabilities for 1988 that Mr. Morris paid during that            
                                                             (continued...)           




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