Michael J. Fitzpatrick - Page 10

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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            
               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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