Evert E. and Eva F. Berglund - Page 13

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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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