-3-
phrase "With express reservation of all my rights in law, equity
and all natures of law". Respondent considered this return to be
frivolous, and it was not processed.
Respondent issued a notice of deficiency to petitioner based on
information returns received from several payors indicating
payments to petitioner during 1992 as follows:
Type of
Payor Payment Amount
Office Equipment Exchange Wages $1,586
Florida Department of Labor Unemployment 5,962
& Employment Security Compensation
Nationsbank of Texas IRA Distribution 8,408
Kemper Clearing Corp. IRA Distribution 1,000
A.G. Edwards & Sons Dividends 2
A.G. Edwards & Sons Stock Sale Proceeds 1,466
A.G. Edwards & Sons Stock Sale Proceeds 198
UCF Federal Credit Union Interest 22
Respondent determined petitioner's tax under section 1(c)
for unmarried individuals. The deficiency in income tax includes
the 10-percent additional tax imposed by section 72(t) on early
distributions from qualified retirement plans. Respondent also
determined that petitioner was liable for additions to tax under
section 6651(a)(1) for failure to file a timely return and under
section 6654(a) for failure to make estimated tax payments.
OPINION
Respondent's determinations are presumed correct, and
petitioner bears the burden of proving otherwise. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933).
1. Gross Income
Section 61(a) defines gross income as "all income from
whatever source derived". The burden is on petitioner to
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