Estate of Frank Johnson - Page 157




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          no adjustment is required for that item in Sylvia’s source and              
          application of funds analysis for 1988.                                     
                    b.  Birthing Costs for Nicole                                     
               In the source and application of funds analysis for Sylvia             
          for 1988, see infra Appendix G, respondent included as an                   
          application of funds $2,500 for birthing costs for Nicole                   
          Johnson, Sylvia’s daughter.  In an affidavit dated November 15,             
          1995, Sylvia stated that Frank and Katherine paid her medical               
          bills relating to Nicole’s birth.  Respondent does not explain              
          how the $2,500 was derived other than by estimation.  Petitioners           
          do not explain why they disagree with this item.  The record                
          indicates that Nicole was born in 1988, but it does not show the            
          amount of medical expenses attributable to her birth nor when               
          those expenses were paid.  On the basis of the foregoing, we                
          conclude that it is not reasonable to include $2,500 birthing               
          costs as an application of funds in Sylvia’s source and                     
          application of funds analysis for 1988; accordingly, we hold that           
          Sylvia’s applications of funds for 1988 should be reduced by                
          $2,500.                                                                     
                    c.  Estimated Tax Payments                                        
               In the source and application of funds analysis for Ronnie             
          for 1988, see infra Appendix G, respondent included as an                   
          application of funds $1,500 for estimated tax payments made                 
          during 1988.  Ronnie’s tax return for 1988 shows $3,000 estimated           






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