Larry Jackson Beard and Gloria Dean Beard - Page 7

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               During 1991, petitioners made car insurance payments and               
          purchased clothes for two of their children, Jacqueline and                 
          Johnathan, for which they were reimbursed.  Petitioners provided            
          canceled checks to corroborate their testimony regarding these              
          reimbursements.  The amounts represented by these reimbursements            
          in the deposits, therefore, are not subject to tax.2  On the                
          basis of the record, we are persuaded that for 1991, Jacqueline             
          and Johnathan reimbursed petitioners $1,000 and $700,                       
          respectively, for car insurance and $200 each for clothes.                  
               During 1991, petitioners took various trips with certain               
          other individuals.  Petitioners sometimes would charge the entire           
          cost of the trip on their credit card, and the other individuals            
          would then reimburse them for their share of the cost.                      
          Petitioners testified credibly regarding the reimbursements for             
          these trips and provided credit card statements for                         
          corroboration.  Patricia Hurst, a travel companion, also                    
          testified credibly regarding reimbursements made to petitioners             
          for certain trips.  Accordingly, the amounts represented by these           
          reimbursements in the deposits, described more fully below, are             
          not subject to tax.                                                         


               2    The reimbursements from Jacqueline and Johnathan for              
          1991 were a combination of checks and cash.  Petitioners and                
          respondent agree that the checks payable to Jacqueline and                  
          Johnathan that were deposited into petitioners' account in 1991             
          are nontaxable.  The difference between our determination of the            
          total reimbursement from the children and the agreed-upon amounts           
          in the form of checks is the resulting cash reimbursement.                  



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