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from creditors, money deposited in a bank account outside the
United States. Gleave was sentenced to Federal custody for 27
months (2 years’ probation and 3 months to be served in a half-
way house) and a fine of $5,000. Also, on this date Gleave was
found guilty of another count of bankruptcy fraud; however, the
conviction on this other count was reversed by the United States
Court of Appeals for the Second Circuit.
_______________________________
Kenmore’s various business activities are collectively the
source of its unreported income.
Respondent has shown by clear and convincing evidence that
none of Kenmore’s suggested nontaxable sources (other than the
$6,600 per year purchase-money mortgage payments) explains
Kenmore’s unreported income.
The amounts shown supra in tables 8, 9, and 10 as “Income to
Gleave” and “Burden of Proof” in the columns headed “Court’s
Redeterminations” were not Kenmore’s repayments of loans from
Gleave.
For each of its fiscal 1980, 1981, and 1982 years, Kenmore
had an underpayment of income tax required to be shown on its tax
return; some part of the underpayment for each of these years was
due to Kenmore‘s fraud.
For each of the years 1980, 1981, and 1982, Gleave had an
underpayment of income tax required to be shown on his tax
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