- 23 - those years. Respondent determined those adjustments on the basis of a source and application of funds analysis for each of those years. Subsequently, respondent closed Sylvia’s audit without issuing a notice of deficiency. D. Source and Application of Funds Analyses Following trial, the parties met in an effort to resolve their differences regarding the source and application of funds analyses for the Johnson family members. In a joint finding of fact set forth in their opening briefs, the parties indicate that Appendix 5 of respondent’s opening brief shows in black the items of the source and application of funds analyses for which the parties are in agreement, and that Appendix 5 shows in red the items for which the parties are not in agreement. We show the items reflected on respondent’s Appendix 5 in our Appendices A through I. To the extent possible, in those appendices, we have incorporated explanations for the differences in amounts reflected on the source and application of funds analyses for Frank and Katherine as gifts to Larry, Ronnie, and Sylvia, from the amounts reflected as excess applications of funds over sources of funds on the separate source and application of funds analyses for Larry, Ronnie, and Sylvia. Except for the items specified below, the parties agree on the amounts shown in source and application of funds analyses set forth infra in Appendix A.Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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