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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts and the attached exhibits are
incorporated herein by this reference. At the time they filed
their petition, Mr. Morin and Marilee D. Morin (Mrs. Morin),
husband and wife, resided in Yakima, Washington.
In 1993, 1994, and 1995, Mr. Morin earned $50,712, $55,118,
and $32,547, respectively, from Les Morin Subaru as compensation
for his services. In 1993 and 1995, Mr. Morin received prizes
from Subaru of America, Inc., in the amounts of $650 and $625,
respectively.
In 1994, Mr. Morin received a retirement account
distribution from Common Sense Shareholder Services in the amount
of $1,974. Mr. Morin had not yet attained the age of 59� at the
time he received this distribution.
OPINION
Section 61 defines gross income as all income from whatever
source derived. Gross income includes compensation for services.
See sec. 61(a)(1). Unless certain exceptions apply, prizes,
awards, and any amount received from an annuity (including a
retirement plan) are gross income. See secs. 72, 74. In
general, the Commissioner's determinations in a notice of
deficiency are presumed correct, and taxpayers bear the burden of
proving them erroneous. See Rule 142(a).
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Last modified: May 25, 2011