Estate of Sylvia Gore, Donor, Deceased, Pamela Powell, Personal Representative - Page 55




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          $41,777 of dividends paid during the first 6 months of 1997 was             
          never deposited into GFLP account No. 7045 or why dividend and              
          interest income generated by Marital Fund assets allegedly                  
          transferred to GFLP was not transferred to the GFLP account after           
          it was deposited into non-GFLP accounts.                                    
               Petitioner relies on the GFLP accounting records prepared by           
          Ms. Bowers after decedent’s death to support petitioner’s                   
          arguments that decedent released all ownership, dominion, and               
          control over Marital Fund assets when she executed the assignment           
          on January 8, 1997.  However, the accounting records were created           
          months after the various transactions occurred and are not                  
          credible.  We view the GFLP accounting records as just one more             
          argument regarding how the Marital Fund assets should have been             
          handled after the January 8, 1997, assignment.  The GFLP                    
          accounting records represent nothing more than a self-serving and           
          belated attempt to create the appearance that decedent                      
          transferred property to GFLP, that GFLP treated all of the bank             
          accounts held in decedent’s and Sidney Gore’s names as its own              
          property, and that GFLP received all income from Marital Fund               
          assets after January 8, 1997.                                               
               As an additional explanation for decedent’s treatment of the           
          income generated by Marital Fund assets, petitioner argues that             
          the income decedent retained was actually owed to her by GFLP as            
          payment for assets that decedent sold to GFLP.  According to                






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