- 3 - burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Section 61(a) includes in gross income all income from whatever source derived including, but not limited to, compensation for services. Sec. 61(a)(1). American Petitioner concedes that he received $300 for services performed as American's employee. We hold that such amount is includable in his gross income. Sec. 61(a)(1). D&B Petitioner concedes that he received nonemployee compensation from D&B for services performed during 1993. He disputes, however, respondent's determination that he received a total of $2,099 from D&B. Respondent submitted photocopies of 10 of D&B's canceled checks made out to petitioner in the total amount of $2,099. At trial, petitioner verified his signature on photocopies of the back of each of the 10 checks. Based on this evidence and petitioner's concession, we find that he received nonemployee compensation from D&B in the amount of $2,099 during 1993 and hold that such amount is includable in his gross income and is subject to self-employment taxes. Bryant Petitioner concedes that he received $2,025 for services performed for Bryant. He does not concede, however, that he is subject to self-employment taxes for such amount.Page: Previous 1 2 3 4 Next
Last modified: May 25, 2011