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v. Commissioner, 431 F.2d 1222 (9th Cir. 1970), affg. T.C. Memo.
1968-257. Respondent must prove any increase in those
deficiencies asserted in her amended answer. Rule 142(a); see
also Robinson v. Commissioner, 102 T.C. 116, 124 (1994), affd. in
part and revd. on another issue 70 F.3d 34 (5th Cir. 1995);
Estate of Bowers v. Commissioner, 94 T.C. 582, 595 (1990).
Section 61(a) defines gross income as "all income from
whatever source derived." Sec. 61(a)(1). This definition
includes all "accessions to wealth, clearly realized, and over
which the taxpayers have complete dominion." Commissioner v.
Glenshaw Glass Co., 348 U.S. 426, 431 (1955); Hawkins v. United
States, 30 F.3d 1077, 1079 (9th Cir. 1994).
Although a taxpayer has the legal right to minimize his
taxes through legally permissible means, see Gregory v.
Helvering, 293 U.S. 465, 469 (1935), this right does not permit
the taxpayer to structure a paper entity to avoid tax when that
entity lacks economic reality. See Markosian v. Commissioner,
73 T.C. 1235, 1241 (1980). When the form of the transaction has
not altered any cognizable economic relationships, we look
through that form and apply the tax law according to the
substance of the transaction. Furman v. Commissioner, 45 T.C.
360 (1966), affd. per curiam 381 F.2d 22 (5th Cir. 1967).
Our review of the record shows that petitioner is liable for
deficiencies for the subject years equal to the amounts asserted
by respondent in here second amendment to answer. The record
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