- 80 - 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of funds analyses to account for the $43,101 gift because there is no evidence that any of the money in the account was withdrawn during that year.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 salesPage: Previous 70 71 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 Next
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