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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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Last modified: May 25, 2011