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calculations, (1) what respondent determined in the notice of
deficiency, (2) what respondent contends on brief, and (3) what
the Court has redetermined.
Table 3
Fiscal 1981
Item Respondent-- Respondent-- Court’s
Def. Notice Brief Findings1
Increase in
gross receipts $1,072,790.42 $991,918.10 $985,318.11
Less: Increase
in purchase 324,117.74 464,816.45 474,398.83
Net 748,672.68 527,101.65 510,919.28
Legal fees
disallowed2 750.00 750.00 750.00
Taxable income
omitted 749,422.68 527,851.65 511,669.28
1 These findings (and those in tables 4, 5, and 7, infra) are
amounts that respondent has shown by clear and convincing
evidence. As indicated infra in part II.A., for purposes of
determining the amounts of deficiencies without regard to fraud,
$6,600 is to be added to the amounts shown in tables 3 and 4 as
taxable income omitted.
2 These disallowed legal fees consist of a check in the amount
of $250 (#334), which petitioners concede was for a personal
obligation of Gleave, and a check in the amount of $500 (#414),
which was used to pay legal fees associated with the Eggertsville
Inn, a personal investment of Gleave, as discussed infra 1980--
Gleave Income--Clear and Convincing.
Table 4
Fiscal 1982
Respondent-- Respondent-- Court’s
Item Def. Notice Brief Findings1
Increase in
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