David C. Sylvester - Page 7




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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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