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As of the date of trial, petitioner had not contacted the
Commonwealth Court requesting access to the $62,275.62 that the
district had deposited with Dauphin Deposit Bank and Trust Co.
for her benefit. Petitioner has never filed a Federal income tax
return for the taxable year 1992.
OPINION
Gross Income
The first issue is whether petitioner is required to include
$138,799.18 in compensation for services, backpay, and interest
on backpay in her 1992 gross income. Gross income includes
income from whatever source derived, including compensation for
services. See sec. 61(a)(1).
A. Compensation for Services Performed During 1992
At trial, petitioner acknowledged that she received and
cashed paychecks for services performed in 1992. Since
compensation for services rendered is includable in gross income
and petitioner does not dispute that she received it, we hold
that petitioner is required to include $38,223.86 of wages for
services that she performed in 1992 in her 1992 gross income.
B. Backpay and Interest on Backpay
With regard to the backpay and interest on backpay,
petitioner appears to argue, in the alternative, that: She never
constructively received these amounts; the money was a damage
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