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station's electronic equipment. Petitioner received $44,628.52 in
wages from KBC; $6,360.58 was withheld for Federal income tax
purposes.
Petitioner had an individual retirement account (IRA) at Key
Trust Co. of the Northwest. During the year in issue, he received
a $49,872 distribution from this IRA. Petitioner did not roll over
the distribution into a qualified retirement account.
Petitioner also received $201.14 in interest income from
Seattle Telco. Federal Credit Union in 1992.
Notice of Deficiency
Respondent found no record of petitioner's having filed a Form
1040 for 1992. Accordingly, respondent determined the deficiency
and additions to tax (set forth in the notice of deficiency) based
upon payor information indicating that petitioner had received
unreported wage, interest, and IRA income in 1992.
OPINION
Issue 1. Unreported Income
Respondent's determinations as to petitioner's tax liability
are presumed to be 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).
Section 61 defines gross income as all income from whatever
source derived. Included within the definition of gross income
are "compensation for services", "interest income", and "pensions".
Sec. 61(a)(1), (4), (11).
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