-29-
sometimes referred to as Watkins.19 During 1982, Maximum
Management wrote 47 checks totaling $6,049.81 to Watkins.20
These 1981 and 1982 payments by Maximum Management to Watkins
were for Watkins' services in taking care of petitioners'
children.
All $5,525.92 ($300 to Monica, plus $5,225.92 to Watkins)
was 1981 net profit of Maximum Management, and so was 1981 income
to petitioners. All $6,049.81 was 1982 net profit of Maximum
Management, and so was 1982 income to petitioners.
18(...continued)
amounts as to 8 of these 44 checks from the only source that
respondent cites. Our finding is in accordance with the sum of
the amounts in the cited exhibit, which is $125.37 less than the
sum of the amounts in respondent's proposed finding of fact.
19 The cited source for respondent's proposed finding of
fact shows that five other checks, totaling $562.51, were written
by Maximum Management to Watkins between Jan. 16, 1981, and Feb.
13, 1981. Respondent has not included these checks in the
proposed finding of fact; we treat this as respondent's
concession that these five payments by Maximum Management to
Watkins did not result in income to petitioners.
20 Respondent's proposed findings of fact list three
additional checks to Watkins, totaling $352.97, and ask us to
find that those checks also gave rise to income to petitioners.
The first of these checks does not appear in the exhibit that
respondent cites as the sole source for the proposed finding.
The second of these checks does appear in the cited exhibit, but
was voided; indeed the next check, which respondent also includes
in the proposed finding of fact, shows that it was written to
replace the voided check. The third of these checks, is shown in
respondent's proposed finding of fact as being made out to
Watkins in the amount of $119.83; in the cited exhibit it is made
out to Central Trust Co. in the amount of $3,874.05. We conclude
that none of these three checks is income to petitioners.
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