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estate distributions. These facts are inconsistent with Gleave’s
testimony. Also, Gleave, who is the sole source of the evidence
that the 1980 inheritance was deposited as a loan into Kenmore’s
Account and not repaid by Kenmore, certified under penalty of
perjury in the bankruptcy petitions in effect that Kenmore did
not owe him any money in 1982. Gleave’s certification is
inconsistent with Gleave’s testimony. We note that $23,540.62 of
proceeds from the sale of Gleave’s mother’s house was deposited
into Kenmore’s Account on September 10, 1980, just 8 days after
the apparent distributions from Gleave’s grandmother’s estate.
This deposit has been excluded from Kenmore’s income as a
nontaxable deposit (supra table 5, note 1), and Kenmore’s checks
to Gleave shortly thereafter have been excluded from Gleave’s
income. It is conceivable that Gleave may have confused this
transaction with the apparent inheritance. We have already taken
account of this transaction.
We conclude that the apparent inheritance is not a
nontaxable source of gross receipts to Kenmore.
Petitioners assert that “Kenmore routinely cashed checks for
many of its suppliers and other persons involved in related
businesses, all of which checks went through its account, but
were incorrectly attributed to * * * Kenmore as income.” We have
found that Kenmore routinely kept thousands of dollars, sometimes
tens of thousands of dollars in its safe. The deposits into
Kenmore’s Account often included currency. From this we conclude
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