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Kenmore’s principal business location was in Kenmore, at 747
Kenmore Avenue, hereinafter sometimes he referred to as the
Kenmore location. The gasoline station business that Kenmore
operated at the Kenmore location will hereinafter sometimes be
referred to as the Kenmore station.
Gleave did not file Federal income tax returns for any of
the years in issue.4 However, Gleave caused Kenmore to file
Federal corporate income tax returns for its fiscal years ending
August 31 of 1980, 1981, and 1982. These tax returns were
prepared by Kenmore’s accountant, Norbert Schechter, C.P.A.,
hereinafter sometimes referred to as Schechter. Kenmore’s 1980
and 1981 tax returns were signed by Gleave.
During the years in issue Gleave did not have a checking
account in his own name in any financial institution in the
United States, and it appears that Gleave did not keep personal
records. During the years in issue Kenmore had a checking
account in its name at M & T Bank. This account will hereinafter
sometimes be referred to as Kenmore’s Account. Gleave used
Kenmore’s Account for his personal banking. Many (if not all) of
Gleave’s personal expenses were paid out of Kenmore’s Account.
Kenmore
4 For each of the years in issue, Gleave’s tax status is
married filing separately; he is not entitled to a dependency
deduction for his wife; and he is not entitled to the standard
deduction but must itemize his “below-the-line” deductions. Sec.
63(e)(1)(A).
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