Gabriel M. Daya, et al. - Page 22




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          to his father was that his mother used funds from the household             
          checking account to purchase food for the family and to pay                 
          household expenses.  The record does include copies of checks               
          drawn from the various accounts which provide some evidence of              
          support expenditures.  Aside, however, from a summary of                    
          disbursements from Morhaf’s checking account in 1995, petitioners           
          have provided us with no evidence of the nature of the                      
          expenditures beyond what we are able to infer from the record and           
          the name of the payee on the checks.                                        
               From the evidence presented at trial, we are able to identify          
          a total of $11,095.15 as 1995 expenditures for the support of the           
          Mahmoud Daya family within the meaning set forth in section 1.152-          
          1(a)(2)(i), Income Tax Regs.  The total amount of identified                
          support expenditures in 1995 includes:  (1) $3,735.99 from the              
          household checking account; (2) $3,671.94 from Morhaf’s checking            
          account; and (3) $3,687.22 from Mahmoud and Laila’s checking                
          account.  The following is a summary of the expenditures from each          
          of these accounts which we have identified as constituting                  
          support:                                                                    
                     Household Checking Account                                       
               Payee                         Amount                                   
               Ghassam Khalar D.D.S.         $215.00                                  
               TCI Cablevision               259.21                                   
               Pacific Bell             2,880.78                                      
               P.G.&E.                       164.00                                   
               DMV Renewal                   217.00                                   
               Total                    3,735.99                                      





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