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Entities Controlled
By Mr. Morris 1987 1988 1989
Accu-Data $11,775.00 $21,875.00 $6,350.00
Trust 768 -- 3,969.91 --
Meadows -- 750.00 9,974.00
MCIC -- 4,550.00 1,820.00
Total 11,775.00 31,144.91 18,144.00
In addition, during 1988, checks drawn by Mr. Morris on the Trust
768 account totaling $19,864.72 were used to pay the joint
Federal and State income tax liabilities that Mr. Morris and
petitioner owed for 1986 and 1988.
The focus of the disagreement of the parties under section
6013(e)(1)(C) is on the funds derived from the bank accounts of
Accu-Data, Trust 768, Meadows, and MCIC that were received by or
expended on behalf of petitioner during the years at issue. We
have found that those funds totaled $11,775, $51,009.63, and
$18,144 during 1987, 1988, and 1989, respectively.23 Respondent
23 We were unable to find on the record before us, as respondent
contends, that petitioner also benefited during 1987 from pay-
ments totaling $5,225.60 that Accu-Data made to GMAC on a loan
that financed the family car or that during 1988 and 1989 all of
the funds deposited into the Meadows account at the Champaign
National Bank and the Meadows account at the National Bank of
Monticello were available to petitioner. With respect to the
Accu-Data payments to GMAC during 1987, although petitioner does
not dispute that those payments were made, she contends that they
were not made for the purpose alleged by respondent. We have
found that Accu-Data made three payments to GMAC, each in the
amount of $250.32, on July 10, Aug. 6, and Sept. 10, 1987, and
that it also paid GMAC $4,464.64 and $10 on Sept. 11 and 24,
1987, respectively. We have further found that petitioner wrote
a check to GMAC in each of the months January through May 1987 in
the amount of $250.32 and in June 1987 in the amount of $250.31.
Although it appears that Accu-Data assumed payments on a loan
from GMAC that petitioner had been paying, there is no evidence
(continued...)
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