- 32 - 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.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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