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that year. See infra Appendices (A), (I). Petitioners maintain
that the gift consisted of a deposit of $43,101 which Frank and
Katherine made into a joint account in Larry’s and Ronnie’s
names.
Respondent maintains that no adjustment is required in
Larry’s or Ronnie’s source and application of funds analyses to
account for the $43,101 gift because there is no evidence that
any of the money in the account was withdrawn during that year.
Thus, respondent maintains, the $43,101 gift would have no impact
on the source and application of funds analysis for Larry or
Ronnie because the gift would be both a source of funds upon its
transfer to the account and an application of funds at the close
of the year in an equal amount. We agree with respondent that no
adjustment is required for this item because petitioners did not
show a net change in the bank account balance, and we hold
accordingly.
3. Adjustment for Proceeds of Automobile Transactions
Petitioners assert that respondent failed to credit Frank
and Katherine with the proceeds from at least three automobiles
that Frank sold or traded during the years in issue. See infra
Appendix A. Respondent maintains that no adjustment is needed
for the proceeds of the three alleged automobile transactions
because the record does not establish that those transactions
occurred nor do petitioners quantify the trade-in value or sales
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