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allowable fiscal 1981 credit. Arc Elec. Const. Co. v.
Commissioner supra; Golsen v. Commissioner, 54 T.C. 742 (1970),
affd. 445 F.2d 985 (10th Cir. 1971). Accordingly, we do not in
the instant cases determine what is the nature of the claimed
carryback, nor do we at this time reconsider our holding in Arc
Elec.
We hold for respondent on this issue.
B. Gleave
(1) Underpayment of Tax
We have found that respondent has shown by clear and
convincing evidence that Gleave had income subject to tax in the
following amounts: 1980--$22,323.54; 1981--$13,719.80; 1982--
$106,038.75. Supra tables 8, 9, and 10. We have found that
Gleave is entitled to deductions that exceed the zero bracket
amount for each of these years. Supra note 8 and associated
text. It is evident, however that the deductions are not large
enough to eliminate Gleave’s tax liability for any of these
years. Gleave did not file tax returns for any of these years.
Accordingly, in the instant cases we conclude that Gleave’s
entire tax liability for each year is a deficiency for that year
and an underpayment for that year. Sec. 6653 (c).
We discuss several of the items that led to the conclusions
that Gleave has an underpayment of tax for each of the years in
issue.
(a) Gleave Loans to Kenmore
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