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Respondent asserts that the transfers from Landing, into the
R&S and Pares Y Nones, S.A. accounts and the repairs by Landing
to petitioner's home constituted income in the respective amounts
of $50,000 and $206,087 for 1981 and 1982. Petitioner argues
that the deposits were loans, rather than income. We agree with
respondent.
Section 61(a) defines gross income as "all income from
whatever source derived." This definition includes all
"accessions to wealth, clearly realized, and over which the
taxpayers have complete dominion", including bribes. Sec. 61(a);
Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955);
Hawkins v. United States, 30 F.3d 1077, 1079 (9th Cir. 1994);
Blohm v. Commissioner, 994 F.2d 1542, 1549 (11th Cir. 1993),
affg. T.C. Memo. 1991-636; United States v. Wyss, 239 F.2d 658
(7th Cir. 1957); sec. 1.61-14(a), Income Tax Regs.
Respondent's determinations are presumed correct, and
petitioner has the burden to establish that they are erroneous.
Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933). Some
courts have recognized a limited exception to this general rule
where the Commissioner alleges that the taxpayer has unreported
illegal income. Petzoldt v. Commissioner, 92 T.C. 661, 688
(1989). In such cases, the deficiency determination must be
supported by some evidentiary foundation linking the taxpayer to
the alleged income-producing activity. Blohm v. Commissioner,
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