Gabriel M. Daya, et al. - Page 23




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                    Morhaf’s Checking Account                                         
               Item                          Amount                                   
               Utilities                     $1,776.13                                
               Household                     668.74                                   
               Transportation                1,096.07                                 
               Medical & Dental                 131.00                                
               Total                         3,671.94                                 
               Mahmoud and Laila’s Checking Account                                   
               Payee                         Amount                                   
               P.G.&E.                       $2,041.44                                
               Estero Utility Services       457.30                                   
               Pacific Bell                  889.50                                   
               B.F.I.                        123.84                                   
               T.C.I.                           175.14                                
               Total                         3,687.22                                 
               The only expenditures we can identify as constituting support          
          for the Mahmoud Daya family in 1996 within the meaning set forth            
          in section 1.152-1(a)(2)(i), Income Tax Regs., are the payments             
          from the household account to Pacific Bell totaling $1,212.40.              
               It is evident from the record that many items required to be           
          included in the total support calculation are absent in both                
          years.  Petitioners have failed to provide any evidence of                  
          expenditures made for food or clothing.  They also have not                 
          provided evidence of the fair rental value of the Foster City               
          residence.                                                                  
               Petitioners rely on the mortgage interest and property tax             
          payments made on the Foster City residence during the years at              






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