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Gross income includes all income from "whatever source
derived". Sec. 61(a). The Supreme Court has consistently held
that section 61 subjects to taxation all accessions to wealth
that are clearly realized over which a taxpayer has complete
dominion and control, unless specifically excluded by statute.
Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955).
Moreover, the elimination of a taxpayer's debt, in whole or in
part, may result in an accession to wealth. Sec. 1.61-12(a),
Income Tax Regs.
Respondent introduced the following evidence that petitioner
received a $15,000 finder's fee from Jack Ham: During a
deposition taken before petitioner's criminal trial, Jack Ham
testified that he owed petitioner a finder's fee because
petitioner helped him obtain a $2.5 million construction loan.
Moreover, Bert Ham testified at trial of this case that he and
Hood both knew that Jack Ham owed petitioner a finder's fee. In
fact, sometime prior to August 1978, the Hams met with Hood at
the Capitol in order to discuss the progress of the construction
loan. During that meeting, Hood telephoned petitioner about the
loan, who indicated that he would call Nelson, the president of
Commerce Bank regarding the matter. Furthermore, petitioner
conceded at trial that he indeed contacted Nelson in an effort to
help the Hams get financing. Shortly after speaking with Nelson,
the Hams received the $2.5 million loan. Bert Ham further
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