Chrys L. Udoh - Page 9




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          petitioner testified that some items were stolen, and the police            
          were unable to provide petitioner with a record of the stolen               
          items.  Petitioner provided the Court with a copy of a request              
          for the police report which showed the incident occurred in 1993.           
          The tax years before us are 1994 and 1995, not 1993, so any items           
          stolen should not affect the years in issue.  For the foregoing             
          reasons, respondent is sustained on this issue.                             
          2.   Unreported Income                                                      
               A.  Insurance Sales                                                    
               Respondent determined that petitioner received $1,098 in               
          income from United in 1994, which amount petitioner did not                 
          include in income.  Petitioner concedes that he received this               
          amount as commissions earned.                                               
               Gross income means all income from whatever source derived,            
          including (but not limited to) compensation for services,                   
          including commissions.  See sec. 61(a)(1).  Although petitioner             
          concedes he received this amount, he argues that amounts in                 
          excess of $1,098 were taken from him by United due to lapsed                
          policies sold by petitioner.  Petitioner has not provided this              
          Court with any credible testimony or documentation to establish             
          his assertion.  Respondent is sustained on this issue.                      
               B.  Retirement Plan Distribution                                       
               Respondent determined petitioner received $1,422 during 1994           
          from a retirement plan distribution, $440 of which respondent               





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