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Kenmore issued four checks aggregating $112.19 to make Gleave’s
payments on his life and disability insurance policies. On
November 1, 1980, Kenmore issued a check in the amount of $250 to
make Gleave’s payment to an Indiana attorney in connection with
his divorce proceedings. See supra table 3, note 2. On June 10,
1980, Kenmore issued a check to Eastern Airlines in the amount of
$708 to pay for Gleave’s flight to Florida to settle a relative’s
estate.
On December 15, 1980, Kenmore (1) paid $17,500 to Amherst
Delta, Inc., for Gleave to buy for himself an interest in
Eggertsville Inn, Inc., a tavern, and (2) paid $500 to LoTempio &
Brown, a law firm, in connection with this purchase. See supra
table 3, note 2. Kenmore did not own an interest in Eggertsville
Inn, Inc. Kenmore deducted on its fiscal 1981 tax return the
$500 LoTempio & Brown payment. This $500 payment was not an
expense of any trade or business of Kenmore, but was an
expenditure for the benefit of Gleave, in connection with
Gleave’s buying the Eggertsville Inn.
On February 28, 1980, Kenmore issued a check to “cash” in
the amount of $400. Gleave received the $400 and used it to pay
his personal expenses.
1980--Not Income to Gleave
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