- 22 - serving than their testimony that McDonald was to receive no more than $6,000. Based on the evidence, including the flow of funds between petitioners and petitioners’ family members, we hold that the 37 percent to 63 percent ratio determined in the statutory notices is the best approximation of petitioners’ partnership arrangement to share profits and losses. Payments From Gold to Petitioners--Respondent determined that the 1989 payments by check, totaling $8,774 for McDonald and $23,671 for Maynard, from Gold were income to petitioners and should have been reported. Gold also paid for insurance for petitioners and some of their family members, for which respondent did not make a determination or adjustment to petitioners’ 1989 income. Petitioners contend that a part of the amounts paid by Gold represented a $250 monthly automobile allowance and that the remainder, whether received and cashed by McDonald or Maynard, was Maynard’s funds. In that regard, Maynard testified that all of these check payments from Gold, both for automobile and otherwise, are either income or expense reimbursement to him, with the exception of the $250 per month automobile allowance from Gold to McDonald. With respect to McDonald’s automobile expenses, McDonald did not submit any records or documentation to Gold contemporaneously with the monthly payments during 1989. For purposes of trial, McDonald submitted documentation reflecting over $3,000 for automobile expenses, including gasoline charge receipts, repairPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
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