Estate of Ona E. Hendrickson - Page 51





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          joint obligations, of decedent and the children.  They were also             
          used to receive income that belonged solely to the children and              
          to pay obligations for which the children were solely                        
          responsible.                                                                 
               Because of this commingling, the proper classification of               
          the thousands of transactions listed in petitioner's accounting              
          as "children's expenses", "joint expenses", or "decedent's                   
          expenses" is of vital importance.  The classifications presented             
          in petitioner's accounting were performed entirely by Donald                 
          Hendrickson.  Because the books reviewed by Donald Hendrickson               
          had classified the bank account items only as money coming in or             
          money going out, he was required to perform these                            
          classifications, and the resulting allocations, largely on the               
          basis of his recollections of the purposes of the transactions.              
          In addition, Donald Hendrickson generally reviewed only check                
          registers, rather than the canceled checks.  Moreover, we again              
          note that the accounting concerns thousands of transactions over             
          14 years and that Donald Hendrickson did not himself keep the                
          records on which the accounting is based.                                    
               For all these reasons-–and without suggesting any                       
          dishonesty--we believe that petitioner's accounting is not                   
          reliable enough either to establish the precise amount of                    
          decedent's expenses paid by Garry's estate or to serve more                  
          generally as a complete "accounting" of Garry's estate.                      





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