- 9 - adjudication of the action at bar”. In light of this posture, we also sustain petitioner’s evidentiary objections to certain of the stipulated facts and exhibits. The contested evidence addresses only the reinvestment of the condemnation proceeds, and while such information would have been relevant to applicability of sections 1033 and 1034, it has no bearing upon our analysis of the Relocation Act. I. Internal Revenue Code As a general rule, the Internal Revenue Code imposes a Federal tax on the taxable income of every individual. See sec. 1. Section 61(a) defines gross income for purposes of calculating such taxable income as “all income from whatever source derived” and further specifies that gains from dealings in property are included within this broad definition. See sec. 61(a)(3). Section 1001(a) then explains that “gain from the sale or other disposition of property shall be the excess of the amount realized therefrom over the adjusted basis”. The basic principles of tax law would thus require petitioner to recognize as income the amount, $40,000, by which the $65,000 she received from the condemnation of her residence exceeded her $25,000 basis. II. Uniform Relocation Assistance Act The Relocation Act, however, provides contrasting treatment for certain payments received in conjunction with GovernmentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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