Thomas G. Roots - Page 9

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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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