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TATT Companies International d.b.a. Pedus Security Service
reported to respondent that it paid petitioner wages in the
amounts of $11,541 and $8,482 during 1987 and 1988, respectively.
The Department of the Air Force reported to respondent that it
paid petitioner a pension annuity in the amount of $8,165 during
1988. Morgan Shareholder Services Trust Company of AMR
Corporation (Morgan) reported to respondent that on February 13,
1987, petitioner sold some securities. Morgan reported that
petitioner received "stock&bond" income in the amount of $56 as a
result of the sale.
Petitioner did not file Federal income tax returns for his
1987 and 1988 taxable years.
Petitioner filed three bankruptcy petitions in the United
States Bankruptcy Court for the District of Arizona since filing
his petition in this Court. In dismissing his third bankruptcy
petition, the presiding judge concluded that petitioner is "a
serial filer and that [his] action as a serial filer constitutes
an abuse of the bankruptcy system."
The first issue for decision is whether petitioner received
and failed to report income during the taxable years in issue.
Section 61(a) includes in gross income all income from
whatever source derived including, but not limited to,
compensation for services, gains from dealings in property,
annuities, and pensions. Sec. 61(a)(1), (3), (9), (11).
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Last modified: May 25, 2011