Venture Funding, Ltd. - Page 39

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               The Code sections providing that different types of                    
          accessions to wealth constitute gross income use various forms of           
          the word "include".  Section 61(a) provides that "gross income              
          means all income from whatever source derived, including (but               
          not limited to) the following items:" and then lists 15 items               
          specifically included in gross income.  Section 61(b) provides:             
          "For items specifically included in gross income, see part II               
          (sec. 71 and following).  For items specifically excluded from              
          gross income, see part III (sec. 101 and following)."  Section 79           
          uses the same articulation as section 83 in providing that the              
          cost of employees' group-term life insurance "shall be included             
          in the gross income" of employees.  The same is true for                    
          reimbursed moving expenses under section 82.  Other Code sections           
          convey the same meaning by different terms such as providing that           
          "gross income includes" alimony (section 71), annuities (section            
          72), prizes and awards (section 74), and Social Security benefits           
          (section 86).  Section 80(a) provides that the restoration of               
          value of certain securities "shall, except as provided in                   
          subsection (b), be included in gross income".  Subsection (b)               
          then provides for reducing "The amount otherwise includible in              
          gross income under subsection (a)" (emphasis added), using the              
          term "includible" to refer to what was previously "included" in             
          gross income.  In another variation, section 88 provides that               
          nuclear decommissioning costs that are built into costs of                  






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Last modified: May 25, 2011