Janice L. Morris - Page 32

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               We note initially that, in the Schedules E of the joint                
          returns that petitioner and Mr. Morris filed for 1988 and 1989,             
          they reported aggregate income from Accu-Data and Meadows of                
          $24,929 and $18,987, respectively.  Consequently, the funds                 
          derived from certain 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 exceeded the amounts of any            
          income of such entities that were reported in the joint returns             
          for 1987 and 1988 (excess funds) by $11,775 and $26,080.63,                 
          respectively, and did not exceed the amount of such income                  
          reported in the joint return for 1989.  On the instant record, we           
          find that it was not unreasonable for petitioner not to have                
          inquired into the source of 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 1987,                
          1988, and 1989 to the extent that the joint returns for those               
          years included income from those entities.                                  
               The question we must now resolve is whether the excess funds           
          for 1987 and 1988 were significant enough that, under the cir-              
          cumstances surrounding petitioner, she should have investigated             
          the source of those funds.24  Based on our examination of the               
          entire record before us, we find that petitioner had no reason to           
          believe that (1) the $11,775 of excess funds derived from the               

          24  We are limiting our inquiry to 1987 and 1988 because there              
          were no excess funds for 1989.                                              




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