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and that as a dependent earning less than $2,500 of income in any
given year, petitioner wife was not required to report that
income.
Section 61(a)(1) defines "gross income * * * [to mean] all
income from whatever source derived, including (but not limited
to) * * * Compensation for services". "Wages * * * are income to
the recipients". Sec. 1.61-2(a)(1), Income Tax Regs. Income has
also 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. See id. at 430.
Therefore, petitioner wife's wages must be included in
petitioners' gross income and may be excluded therefrom only if
allowed under some provision of the Internal Revenue Code.
The theory advanced by petitioners for the exclusion of
petitioner wife's wages from income is not supported by any
statutory basis. First, under section 152(a), the term
"dependent" clearly does not include a spouse.4 Second, even if
4 To qualify as a "dependent" within the meaning of sec.
152(a), an individual must either be related to the taxpayer in
one of the 8 specific ways enumerated by the statute, see sec.
152(a)(1) to (8), or be a member of the taxpayer's household for
the entire taxable year, see sec. 152(a)(9). See also sec.
1.152-1, Income Tax Regs. A taxpayer's spouse is not related to
the taxpayer in any of the specific ways enumerated by the
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