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refund check. Nancy first became aware of this tax refund after
Sheldon's death, probably in early 1987.
In 1984 the U.S. Treasury issued to Sheldon and Nancy a
$25,540.14 tax refund check on account of 1982. Sheldon
deposited this check into the same bank account as the earlier
refund check. Substantial withdrawals were not made from this
bank account until about 2 months after this deposit.
During the period December 11, 1980, through December 13,
1984, the balance in this Chemical Bank checking account
fluctuated substantially. Table 4 illustrates these fluctuations
by showing the bank account balances (rounded to the nearest
dollar) on selected dates.
Table 4
Date Amount Date Amount
12/11/80 $11,108 03/23/83 $17,344
12/31/80 609 06/10/83 56,248
03/04/81 41,311 06/28/83 (69,274)
04/20/81 5,681 12/15/83 61,755
09/11/81 27,792 01/12/84 5,083
11/09/81 4,726 02/14/84 123,621
05/07/82 165,572 02/17/84 14,247
06/17/82 12,730 03/09/84 103,005
06/18/82 514,327 04/09/84 (990)
07/08/82 3,737 05/09/84 33,926
09/28/82 97,864 07/23/84 3,253
12/10/82 11,338 07/27/84 46,023
12/20/82 361,221 12/03/84 989
On September 8, 1986, Nancy filed amended joint tax returns
for 1979, 1980, and 1981, claiming refunds of previously paid
taxes, as shown in table 5. On these amended tax returns, Nancy
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