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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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