- 9 - section 7212(a) by knowingly and corruptly endeavoring to obstruct or impede the due administration of the Internal Revenue Code by requesting one of his tenants to lie to the revenue agent about the amount of rent the tenant paid to petitioner. On May 29, 1992, petitioner pled guilty to willfully attempting to evade income taxes for his 1987 taxable year in violation of section 7201 and to willfully attempting to interfere with the administration of internal revenue laws in violation of section 7212(a). On August 10, 1992, the District Court sentenced petitioner to 8 months of imprisonment and 5 years of probation and imposed a $20,000 fine. OPINION A. Unreported Income Respondent determined that certain deposits into petitioner's ACB account constituted unreported income to him. Petitioner argues that the disputed deposits are not taxable to him in the subject years because they were loans or previously taxed income. We agree with respondent. 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). When a taxpayer keeps no books or records for his or her business, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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