- 4 - OPINION Gross Income Under section 61, Congress defined gross income as all income from whatever source derived. See Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 430 (1955); Abrams v. Commissioner, 82 T.C. 403, 407 (1984). This includes income from a business. See sec. 61(a)(2). Petitioners do not challenge respondent’s calculation of petitioners’ income. Petitioners, in fact, stipulate that during 1994, Mr. Knelman received, but failed to report, $14,555 of income from the landscaping business. Notwithstanding the express language of section 61, petitioners contend that they are not required to pay any Federal income tax on this income. Petitioners advance shopworn arguments characteristic of tax-protester rhetoric that has been universally rejected by the courts. See Williams v. Commissioner, 114 T.C. 136, 138-139 (2000); Boyce v. Commissioner, T.C. Memo. 1996-439, affd. without published opinion 122 F.3d 1069 (9th Cir. 1997); Fair v. Commissioner, T.C. Memo. 1994-276, affd. without published opinion 60 F.3d 833 (9th Cir. 1995). Petitioners allege: (1) There are no provisions in the Internal Revenue Code requiring U.S. citizens to pay Federal income tax on income earned in the United States; (2) the income which the landscaping business earned was not gross income andPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011