Joseph Baldwin Campbell - Page 2

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            Respondent determined a deficiency of $8,512 in petitioner's                                 
            Federal income tax for 1992 and additions to tax of $1,915, $681,                            
            and $374 under sections 6651(a)(1) and (2) and 6654(a),                                      
            Following concessions by the parties, as discussed below,                                    
            the issues remaining for decision are:  (1) Whether per capita                               
            distributions to petitioner from the Prairie Island Tribal                                   
            Council arising out of the ownership and operation of a gambling                             
            casino constitute gross income, or whether such income is                                    
            "derived directly" from land owned by the Prairie Island Tribal                              
            Council and is excludable from taxation pursuant to laws,                                    
            treaties, or agreements between Indian tribes and the United                                 
            States Government, and (2) whether unreimbursed expenses incurred                            
            by petitioner in the course of his duties as a member of the                                 
            Environmental Protection Committee of the Prairie Island Tribal                              
            Council are deductible in 1992.                                                              
            Some of the facts were stipulated, and those facts, with the                                 
            annexed exhibits, are so found and are incorporated herein by                                
            reference.  At the time the petition was filed, petitioner's                                 
            legal residence was Welch, Minnesota.                                                        
                  During all years relevant hereto, petitioner was an enrolled                           
            member of the Prairie Island Indian Community in Minnesota and                               

            granted petitioner's motion, at which time respondent filed an                               

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