Lola Cowan - Page 4

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                  Petitioner's failure to timely file a Federal income tax                               
            return was not attributable to reasonable cause within the meaning                           
            of section 6651(a).                                                                          
                                                OPINION                                                  
            Issue 1.  Unreported Income                                                                  
                  Respondent's determinations as to petitioner's tax liability                           
            are presumed correct.  Petitioner bears the burden of proving the                            
            contrary.  See Rule 142(a); INDOPCO, Inc. v. Commissioner, 503 U.S.                          
            79, 84 (1992); Welch v. Helvering, 290 U.S. 111, 115 (1933).                                 
                  Petitioner chose not to call any witnesses or present any                              
            meaningful evidence.  She admitted, when questioned by the Court,                            
            that during 1990 she worked as a teacher's assistant at Echo Glen,                           
            a prison for youngsters, and received wages from Issaquah School                             
            District.  She further admitted not filing a tax return for 1990                             
            and justified her failure to file by stating: "I don't believe that                          
            a person that's working as hard [as I] for as small a wage as I                              
            should have to pay tax."                                                                     
                  Section 61 defines gross income as all income from whatever                            
            source derived.  Included within the definition of gross income are                          
            "Compensation for services", "Gains derived from dealings in                                 
            property", and "Dividends".  Sec. 61(a)(1), (3), (7).                                        
                  The largest amount of unreported income involves petitioner's                          
            sale of property located at 27605 SE 196th Pl., Issaquah,                                    
            Washington (196th Pl. property). Section 1001(c) requires                                    





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