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On September 17, 1981, Kenmore issued a check to Kenmore
Mercy Hospital in the amount of $23. This was in payment of a
charge for the hospital’s emergency room treatment of a Kenmore
employee.
In October 1981, on two occasions, Kenmore issued checks to
M & T Bank to wire funds to repair Kenmore’s trucks that had
broken down a long distance from Buffalo. The checks were in the
amounts of $1,553.39 and $1,448.25.
1981--Other Items--Burden of Proof
Kenmore’s April 17, 1981, check to Western-Southern Life
Insurance Co. in the amount of $2,095.76 was for key-man life
insurance on Gleave’s life.
In addition to the items discussed supra, during 1981
Kenmore issued checks, or otherwise made payments, aggregating
$376,926.37 to “cash” or named payees. The evidence of record as
to the key-man life insurance and these items does not enable us
to conclude that any of these Kenmore payments was--or was not--
income to Gleave.
Table 9 summarizes respondent’s determinations as to
Gleave’s 1981 income subject to tax, and our redeterminations.
Table 9
Respondent’s Court’s
Determinations Redeterminations
Income to Gleave $411,038.63 $13,719.80
Not income to Gleave --- 118,256.28
Burden of proof --- 379,022.13
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