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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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Last modified: November 10, 2007