- 89 - 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.Page: Previous 79 80 81 82 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 Next
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