Leonard Ray Blanton and Betty Blanton - Page 14

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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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