- 55 - 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 KenmorePage: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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