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directly or indirectly from the use of Indian land, or from
services performed on Indian land, or related in any way to
petitioner's status as a member of the Seneca Nation. Respondent
is sustained on this issue.
We hold that petitioner is not exempt from Federal income
taxes either because of his status as a member of the Seneca
Nation, or because of the source of his income in this case.
Furthermore, petitioner was required to file an income tax return
for 1994 because he meets the requirements of section 6012.
2. Bond Interest Income
Petitioner does not question the inclusion in gross income
of wages and unemployment compensation if he is found to be
subject to the Federal income tax. However, petitioner contests
the inclusion of $50 of bond interest income8 for the 1994 tax
year.
Respondent determined that petitioner received $50 in
taxable proceeds in 1994 from A.G. Edwards & Sons, Inc. (A.G.
Edwards). Respondent based his determination on a Form 1099-B
received from A.G. Edwards. At trial, petitioner admitted that
he received $50 of bond interest, but argued that the amount is
8 This income was characterized as bond interest by petitioner
and as "proceeds from broker transactions" by respondent.
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