Joseph Baldwin Campbell - Page 8

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            revg. 79 T.C. 398 (1982) ([all] realized accessions to wealth are                            
            presumed to be taxable income, unless the taxpayer can                                       
            demonstrate that an acquisition is specifically exempted from                                
            taxation.").                                                                                 
                  It is well established that American Indians are subject to                            
            Federal income taxation unless an exemption exists in the                                    
            language of a treaty or an Act of Congress.  Squire v. Capoeman,                             
            351 U.S. 1, 6 (1956); United States v. Willie, 941 F.2d 1384,                                
            1400 (10th Cir. 1991); Cross v. Commissioner, 83 T.C. 561, 564                               
            (1984), affd. sub nom. Dillon v. United States, 792 F.2d 849 (9th                            
            Cir. 1986).  The fact that petitioner is an American Indian does                             
            not preclude him from being liable for the payment of income tax.                            
            Hoptowit v. Commissioner, 78 T.C. 137, 145 (1982), affd. 709 F.2d                            
            564 (9th Cir. 1983).                                                                         
                  Though not specifically addressed in the Internal Revenue                              
            Code, revenue from casino gambling conducted on American Indian                              
            reservations is specifically subjected to Federal taxes under the                            
            Indian Gaming Regulatory Act, Pub. L. 100-497, 102 Stat. 2467,                               
            2472, 25 U.S.C. sec. 2710 (1994).  The Indian Gaming Regulatory                              
            Act provides that "per capita payments [of net revenues from                                 
            gaming activities conducted or licensed by any Indian tribe] are                             
            subject to Federal taxation and tribes [must] notify members of                              
            such tax liability when payments are made."  25 U.S.C. sec.                                  
            2710(b)(3)(D) (1994).  The tribal council did notify petitioner,                             





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