AJF Transportation Consultants, Inc., et al. - Page 14

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             performance of services for which the checks were issued,                                            
             entitling him to deduct such amounts from gross income resulting                                     
             in no underpayment.                                                                                  
                          1.  Fuel Reimbursement Checks                                                           
                    The first question is whether the fuel reimbursement checks                                   
             should be included in AJF's gross income.  Section 61(a) defines                                     
             the term "gross income" as "all income from whatever source                                          
             derived", except as otherwise provided by law.  Income has been                                      
             defined as "undeniable accessions to wealth, clearly realized,                                       
             and over which the taxpayers have complete dominion."                                                
             Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955).                                        
             Unless specifically excluded by another provision of the Internal                                    
             Revenue Code, all income is subject to tax.  Id. at 430.                                             
             Therefore, reimbursed expenses must be included in gross income,                                     
             but these expenses may be deducted only if allowed under other                                       
             provisions of the Internal Revenue Code and if adequately                                            
             substantiated.  Rietzke v. Commissioner, 40 T.C. 443, 453 (1963);                                    
             Vaughn v. Commissioner, T.C. Memo. 1992-317, affd. without                                           
             published opinion 15 F.3d 1095 (9th Cir. 1993).                                                      
                    Petitioners argue that the unreported fuel reimbursement                                      
             checks should not be included in gross income because the checks                                     
             were repayments of a loan made from AJF to J.C. Penney for                                           








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