Estate of Frank Johnson - Page 152




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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          any of the money in the account was withdrawn during that year.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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