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the check and received the money. Contrary to respondent's
assertion, however, the record shows that the insurance company
issued a check for $6,535 on July 30, 1991 and $6,535 was
deposited into the corporation's Merrill Lynch account on August
12, 1991. Mr. Beck did not receive the money. The insurance
payment was for a casualty loss that occurred in the year of the
payment. Respondent has not established that there was a gain on
the receipt of the insurance payment (i.e., that the basis in the
vehicle was less than the amount of the payment). We find that
the payment is income neither to the corporation nor to Mr. Beck.
d. Remaining Cash Payments
Mr. Beck contends that the following cash payments were not
income because they were made with cash Mrs. Beck had accumulated
before her death:
1991 1992 1993
Purchase of ring –- $10,655 –-
Purchase of car –- 9,400 –-
Loan payments $5,000 35,000 $44,000
State Bank CD 27,500 –- –-
Norwest Bank –- –- 4,026
Gate City S&L 9,000 –- –-
Total 41,500 55,055 48,026
At the time of her death, Mrs. Beck had between $50,000 and
$60,000, of which only $26,000 was in cash. The cash
expenditures for 1991 should be reduced to reflect the $26,000
available to Mr. Beck.
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