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for 1992; section 6654(a), $787.23 for 1991 and $356.58 for 1992.
Petitioner has conceded that he received all of the wages and
other items that respondent determined were income. His position
is that he did not earn a profit from any of the sources
determined to be income. More particularly, the questions for
our consideration are: (l) Whether petitioner’s wages or
compensation from services, interest, dividends, gambling
winnings, and proceeds from the sale of stock are income, and (2)
whether petitioner is liable for the additions to tax under
sections 6651(a) and 6654(a) for each of the taxable years 1991
and 1992.
Petitioner resided at Las Vegas, Nevada, at the time his
petition was filed in this case. At trial, petitioner appeared,
but did not wish to testify or offer evidence. He requested that
we decide his case based on a document presenting his position
with respect to respondent’s determination. Petitioner’s
argument as to why the determined items were not income to him
may be summarized as follows: (1) The section 61 definition of
income is inconsistent with Supreme Court opinions that contain
the statement that income equates with the concept of profit, and
petitioner contends that his exchange of services for wages or
compensation is not a profit situation. (2) The right to receive
1(...continued)
effect for the years in issue, and Rule references are to this
Court's Rules of Practice and Procedure.
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Last modified: May 25, 2011