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Between 1992 and 1994, the trust distributed the following
amounts to its three beneficiaries:
Year Amount
1992 $40,000
1993 32,693
1994 49,038
During the years at issue, petitioner and Mr. Goings
maintained at least one joint checking account (the joint
account). Petitioner managed this account. She balanced it
periodically and paid her family's household bills with checks
drawn against it. The couple also maintained a joint investment
account with Merrill Lynch (the Merrill Lynch account).
Petitioner and Mr. Goings opened the Merrill Lynch account in
March 1986 with an initial investment of $150,000. The account
statements for the Merrill Lynch account were sent to the
couple's home. In addition to the two accounts previously noted,
Mr. Goings also maintained an individual account (the individual
account) to which petitioner did not have signatory access.
Petitioner, however, was aware of the individual account and drew
two checks against it by signing Mr. Goings's name. The payments
Bordelon made to Mr. Goings were deposited in the couple's
accounts as follows:
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