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all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issues for decision are: (1) Whether $46,818 that
petitioner received as compensation for services constitutes
taxable income; and (2) whether petitioner is liable for
additions to tax under sections 6651(a)(1) and 6654(a).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
When the petition was filed, petitioner resided in Newport
Beach, California.
In 1993, petitioner received $46,818 as compensation for
services rendered as a lecturer and researcher for Miliken & Co.
For 1993, petitioner did not make estimated tax payments,
and petitioner did not file an individual Federal income tax
return.
On audit, respondent determined that petitioner received the
$46,818 as taxable income. Respondent also determined that
petitioner is liable for the additions to tax.
OPINION
Gross income is defined as all income from whatever source
derived, including compensation for services. Sec. 61(a)(1).
In general, respondent's determinations in a notice of
deficiency are presumed to be correct, and taxpayers bear the
burden of proving that those determinations are erroneous. Rule
142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933).
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Last modified: May 25, 2011