Estate of Frank Johnson - Page 161




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          basis of the foregoing, we conclude that it is not reasonable to            
          include $6,000 for Janie’s living expenses as an application of             
          funds in Frank and Katherine’s source and application of funds              
          analysis for 1990; accordingly, we hold that their applications             
          of funds for 1990 should be reduced $6,000 to account for this              
          item.                                                                       
                    h.  Duplications Regarding Johnson Limousine                      
               In the source and application of funds analysis for Frank              
          and Katherine for 1990, see infra Appendix A, respondent reduced            
          gifts to Larry, Ronnie, and Sylvia by $46,490 to account for                
          duplications regarding Johnson Limousine.  These adjustments are            
          not explained further.  Petitioners do not explain why they                 
          disagree with this item.  Since the adjustment favors petitioners           
          and they do not explain why it should not be made in the amount             
          allowed by respondent, we hold that no adjustment is required for           
          that item in Frank and Katherine’s source and application of                
          funds analysis for 1990.                                                    
                    7.  Other Adjustments                                             
               After reviewing the record and the source and application of           
          funds analyses for the Johnson family members for the years in              
          issue, we believe that the following additional adjustments are             
          needed to calculate excess applications of funds over sources of            
          funds for those years.                                                      








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