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claimed an overpayment in the amount of $495 for withholding
payments. Respondent issued a notice of deficiency based on a
taxable income in the amount of $29,058 and deductions for
personal exemptions and a standard deduction in the respective
amounts of $5,100 and $6,700.
On petitioners' motion, these cases were consolidated for
trial, briefing, and opinion and calendared for trial at the
Court's Trial Session commencing October 5, 1998, in Baltimore,
Maryland. At trial, a stipulation of facts was submitted in each
case signed by respondent and both petitioners. Petitioner
Richard J. Sinsigalli (petitioner) argued petitioners' position.
Petitioners do not dispute that the wages were received, nor do
petitioners dispute respondent's disallowance of the
miscellaneous deductions. Rather, they argue that wages are not
taxable income.
Discussion
Section 61(a)(1) defines "gross income * * * [to mean] all
income from whatever source derived, including (but not limited
to) * * * [c]ompensation for services". "Wages * * * are income
to the recipients". Sec. 1.61-2(a)(1), Income Tax Regs.
Moreover, this Court and all others have consistently rejected
the argument in various forms that wages are not taxable. See,
e.g., Rowlee v. Commissioner, 80 T.C. 1111, 1119-1122 (1983).
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