Charles and Beatrice M. Reynolds - Page 4




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          by letters to petitioners’ March 1998 correspondence to the                 
          Problem Resolution Office.  Respondent’s reply advised of changes           
          to petitioners’ statements of account for both 1993 and 1994 and            
          indicated for each year that “the amount you now owe” is “none”.            
               The parties have stipulated that Exhibit 1-J “is a copy of             
          petitioners’ joint federal income tax return for the year 1993.”            
          Respondent has produced, and the Court has admitted into                    
          evidence, a certified copy of petitioners’ joint individual                 
          Federal income tax return for 1994.                                         
          A.   Medical Expenses                                                       
               Mrs. Reynolds’ mother, Mrs. Maxey, lived in a nursing home             
          in Salem, Virginia, in 1993.  She was 84 years old, suffering               
          from Parkinson’s disease, bedridden, and unable to feed or to               
          care for herself.  There were two other residents of the home               
          where Mrs. Maxey resided.  Mrs. Maxey was provided with around-             
          the-clock care; the proprietor of the home was a registered                 
          nurse.                                                                      
               Mrs. Reynolds’ sister, Judy Maxey, held power of attorney              
          for their mother’s bank accounts.  Mrs. Reynolds had an agreement           
          with her sister and their five brothers that they would share the           
          expense of maintaining their mother in the Virginia nursing home.           
          The family members agreed to make their monetary contributions              
          for their mother’s support to their sister, Judy Maxey.  Judy               
          Maxey would then make the required payments to the nursing home             





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