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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, the
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