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2. Additional Schedule A Deductions
For reasons similar to those stated above, we agree with
respondent that petitioners may not deduct more interest or taxes
on their Schedules A than she has allowed. We hold for
respondent on this issue.
3. Taxability of Unemployment Compensation
Gross income includes unemployment compensation. Sec.
85(a). Given the facts that Mrs. Tillman received $1,152 of
unemployment income in 1989, and that petitioners did not report
this amount on their 1989 tax return, we must hold for respondent
on this issue.
4. Unreported Sales Income
Gross income includes income from whatever source derived.
Sec. 61(a). Petitioners agree that Trucking received $43,621 and
$43,475 in gross receipts from Crawford during 1990 and 1991,
respectively, and that petitioners’ tax returns reported only
$21,424 of these receipts for 1990 and none of them for 1991. We
hold that petitioners failed to report $22,197 in sales income
for 1990, and $43,475 in sales income for 1991.
5. Receipt of Insurance Proceeds
A taxpayer realizes gain on a conversion (e.g., a loss) to
the extent that the insurance proceeds connected thereto exceed
the adjusted basis of the underlying property. Sec. 1001(a).
6(...continued)
taking title, or in which he has no equity.
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