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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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