John Minor - Page 3

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                  The first issue for decision is whether petitioner received                           
            and failed to report income during the taxable years in issue.                              
            Respondent's determinations in the statutory notice of deficiency                           
            are presumed to be correct, and petitioner bears the 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).  At trial, petitioner                            
            admitted that he earned the amounts reported on the Forms W-2 and                           
            determined by respondent in the statutory notice of deficiency to                           
            be includable in his gross income.  Petitioner claims, however,                             
            that he is entitled to a deduction for the amounts of his wages                             
            which were allegedly garnished by order of a Mississippi State                              
            court.                                                                                      
                  Based on the record, we find that petitioner has failed to                            
            prove any error in respondent's determinations.  According to his                           
            testimony, his wages were garnished to repay loan proceeds which                            
            he obtained by forging the signature of another person.  We find                            
            his claim to a deduction for amounts which he is required to pay                            
            to such person to be without merit.  An employer's payment of an                            
            obligation of the taxpayer is equivalent to the taxpayer's                                  
            receipt of income in the amount so paid.  Old Colony Trust Co. v.                           








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