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performance of services for which the checks were issued,
entitling him to deduct such amounts from gross income resulting
in no underpayment.
1. Fuel Reimbursement Checks
The first question is whether the fuel reimbursement checks
should be included in AJF's gross income. Section 61(a) defines
the term "gross income" as "all income from whatever source
derived", except as otherwise provided by law. Income has been
defined as "undeniable accessions to wealth, clearly realized,
and over which the taxpayers have complete dominion."
Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955).
Unless specifically excluded by another provision of the Internal
Revenue Code, all income is subject to tax. Id. at 430.
Therefore, reimbursed expenses must be included in gross income,
but these expenses may be deducted only if allowed under other
provisions of the Internal Revenue Code and if adequately
substantiated. Rietzke v. Commissioner, 40 T.C. 443, 453 (1963);
Vaughn v. Commissioner, T.C. Memo. 1992-317, affd. without
published opinion 15 F.3d 1095 (9th Cir. 1993).
Petitioners argue that the unreported fuel reimbursement
checks should not be included in gross income because the checks
were repayments of a loan made from AJF to J.C. Penney for
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