- 11 - United States, 71 AFTR 2d 93-1735 at 93-1737, 93-2 USTC par. 50371 at 89,033 (D. Colo. 1993); see Beard v. Commissioner, 82 T.C. 766, 774-779 (1984), affd. 793 F.2d 139 (6th Cir. 1986); Sickler v. Commissioner, T.C. Memo. 1994-462; Koeneman v. Commissioner, T.C. Memo. 1958-186. Section 6501(c) provides that in the case of a failure to file a return, the tax may be assessed at any time. Since petitioner failed to file tax returns for the years at issue, the notices of deficiency were timely issued. We hold that the wages and other income attributed to petitioner in the notices of deficiency are taxable income. See Coleman v. Commissioner, 791 F.2d 68, 70 (7th Cir. 1986). Gross income is expressly defined under the Internal Revenue Code as all income from whatever source derived, unless excluded by law, including compensation for services and unemployment compensation. Sec. 61(a), 85; secs. 1.61-1 and 1.61-2, Income Tax Regs. Aside from her frivolous tax protester-type arguments, petitioner offered nothing to contradict the determination of wage and other income in the notices of deficiency, nor did she offer any grounds for excluding those items from her gross income. Petitioner's general protester-type arguments have been rejected by this Court and others, including the Court of Appeals for the Seventh Circuit, to which appeal in this case lies. See Coleman v. Commissioner, supra; see also Crain v. Commissioner,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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