- 47 -
Petitioners’ only contentions as to the 1995 nontaxable transfers
were among the items respondent conceded in the postbrief actions
referred to supra note 24. The parties’ postbriefs concessions
are taken into account in tables 7 and 8, supra.
(3) Returned Checks (NSF)
The parties stipulated that returned checks (insufficient
funds) were not less than $7,132 in 1995.25 Petitioners’ only
contention as to the 1995 returned checks (insufficient funds)
was among the items respondent conceded in the postbriefs actions
referred to supra note 24.
(4) Gifts
The parties stipulated petitioners received as gifts from
relatives checks and cash that were deposited totaling “no less
than” $265 in 1994 and “no less than” $502 in 1995.26
On opening brief, petitioners contend that Sandra
“calculated” that petitioners’ bank deposits included cash gifts
from relatives in the amounts of “about” $2,490 in 1994 and
“about” $5,235 in 1995. On answering brief, petitioners contend
24(...continued)
and $6,000 was agreed to in proceedings under a motion to reopen
the record after the answering briefs were filed.
25 Of this 1995 total, $7,082 was stipulated before trial
and $50 was agreed to in the postbriefs actions referred to supra
note 24.
26 Of this 1995 total, $402 was stipulated before the trial
and $100 was agreed to in the postbriefs actions referred to
supra note 24.
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