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fact occurred. Although we sympathize with petitioner for being
forced to sell approximately 652 acres of farmland against his
will in 1986 due to his nonpayment of outstanding loans, the fact
remains that the property was sold. Despite petitioner's
repeated litigation in courts in the States of Illinois and
Indiana, the bankruptcy court, the District Court, and the Court
of Appeals for the Seventh Circuit, no court has reversed the
foreclosure sale of petitioner's real estate. Petitioner and his
spouse failed to report this foreclosure-sale transaction on
their joint Federal income tax return for 1986. Accordingly, we
sustain respondent's determination with respect to this issue.3
Issue 2. Pension Income
Section 61(a)(11) further elaborates on the section 61(a)
definition of gross income by providing that gross income
specifically includes income from pensions. See sec. 1.61-11,
Income Tax Regs. Petitioner and his spouse's returns for 1986,
1987, and 1988 show that petitioner's spouse received pension
3We note that respondent did not assert an increased
deficiency in this case based upon the increased sale price of
petitioner's farmland. It does not appear that any increased
deficiency will be generated as a result of the increased sale
price of the property in this case because respondent has made
various concessions and conditional concessions. Nevertheless,
we note that the deficiencies ultimately determined under the
Rule 155 computations are limited to the amount of the
deficiencies respondent determined in the statutory notice of
deficiency.
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