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she and Frank gave Larry, Ronnie, and Sylvia funds to purchase
assets and to pay their personal living expenses. Both Frank and
Katherine were deceased by the time of trial.
Petitioners have the burden of proving that respondent’s
determinations as to the amount of the understated income are
incorrect. Rule 142(a). The parties have agreed as to the
amounts reflected on the source and application of funds analyses
for Frank and Katherine, Larry, Ronnie, and Sylvia set forth
infra in Appendices A through I except as noted therein.
Consequently, we focus primarily on the items that the parties
have identified as in dispute. There are a few additional items
in the source and application of funds analyses, however, which
we believe from the record also need to be addressed. Those
items also are discussed below.
1. Adjustments to BLS Figures
Because of the absence of specific information relating to
the Johnson family’s personal living expenses, in the source and
application of funds analyses for Frank and Katherine, Larry,
Ronnie, and Sylvia, respondent used data from Table 4 of the
Bureau of Labor Statistics Consumer Expenditure Survey for each
year in issue to calculate personal living expenditures.
Petitioners contend that respondent’s use of the BLS tables is
flawed because those tables do not accurately reflect Frank and
Katherine’s lifestyle. Petitioners assert that respondent did
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