Estate of Frank Johnson - Page 95




                                       - 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.            








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