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The gist of petitioner's position is common to so-called tax
protesters, despite his repeated claims that he should not be so
pigeonholed. Petitioner admits that he exchanged his labor for
the amounts paid to him during the relevant taxable years.
Nevertheless, petitioner maintains that such an exchange does not
constitute a taxable transaction as long as it was even. Since
the value of his labor equaled or exceeded the value of the wages
and nonemployee compensation he received in exchange therefor,
petitioner theorizes, he did not realize a gain. Therefore, no
part of his remuneration is subject to income tax. In so
arguing, petitioner contends that section 83 authorizes the
requisite specific exclusion from gross income for compensation
received for services rendered, since "[petitioner's basis (cost)
is the * * * [fair market value] of his services, [and] this
amount is deductible as cost" under the statute. Respondent
demurs to all of petitioner's assertions.
We agree with respondent and hold that the wages and other
compensation attributed to petitioner in the notices of
deficiency are taxable income.
"Except as otherwise provided", wages, salaries,
commissions, and other compensation received in consideration of
services or labor performed are included in the recipient's gross
income for income tax purposes. Sec. 61(a)(1); Old Colony Trust
Co. v. Commissioner, 279 U.S. 716, 729 (1929); Tyee Realty Co. v.
Anderson, 240 U.S. 115 (1916); Brushaber v. Union Pac. R.R. Co.,
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