- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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