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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),
respectively.
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
1(...continued)
granted petitioner's motion, at which time respondent filed an
answer.
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