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records relating to their expenditures for the years in issue.
Consequently, in the absence of records, we find reasonable
respondent’s use of BLS data to estimate personal living expenses
for the Johnson family. Petitioners offered no proof rebutting
respondent’s position that, with certain adjustments, Frank and
Katherine, Larry, Ronnie, and Sylvia must have incurred personal
living expenses during the years in issue at least equal to the
amounts reflected in the BLS tables. See Pollard v.
Commissioner, supra. Nonetheless, we agree with petitioners that
additional adjustments to the BLS figures are necessary.
We do not agree with petitioners that the Johnson family
lived together in a communal lifestyle. Although they may have
come together often for meals and vacations, Larry maintained his
own residence during all of the years in issue, Ronnie maintained
his own residence from 1985 through 1990, and Sylvia maintained
her own residence from August through December 1990. Thus, we
agree that personal living expenses should be calculated
separately for Larry, Ronnie, and Sylvia, at least for the
periods they maintained separate households.
Thus, we find reasonable respondent’s methodology of
calculating separately personal living expenses for Larry for all
of the years in issue and for Ronnie for 1985 through 1990.
However, we believe that personal living expenses should be
deleted from Ronnie’s source and application of funds analyses
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