Janice L. Morris - Page 17

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               Accu-Data made three payments to GMAC, each in the amount of           
          $250.32, on July 10, August 6, and September 10, 1987.  It also             
          paid GMAC $4,464.64 on September 11, 1987, and $10 on September             
          24, 1987.                                                                   
               Mr. Morris transferred to petitioner ownership of a life               
          insurance policy with a cash value of $15,000.18                            
          Petitioner's Education, Work                                                
          Experience, and Family Life                                                 
               Although petitioner had worked during 1981 and 1982 as an              
          accounts receivable clerk at a medical supply company, she was              
          not employed during the years at issue.  Rather, during those               
          years, petitioner was a homemaker, mother, and part-time college            
          student.                                                                    
               During the fall of 1982, petitioner, who had not had any               
          post-high school education, entered Parkland College.  She took             
          courses there over the next several years, including two intro-             
          ductory courses in basic accounting principles, and received a              
          degree from that institution in the spring of 1987.  In the fall            
          of 1987, petitioner entered the University of Illinois and took             
          courses there for two years, including two intermediate account-            
          ing courses, before she withdrew to devote more time to her                 
          children.  Sometime after the years at issue, petitioner returned           

          17(...continued)                                                            
          year were attributable to estimated tax payments.                           
          18  The record does not disclose when that policy was transferred           
          to petitioner.                                                              




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