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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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