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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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