William J. Broedel and Joan C. Broedel - Page 17




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               Section 61(a) defines gross income as “all income from                 
          whatever source derived”.  Petitioners offered no evidence or               
          argument to support any claim that the use of funds from Mr.                
          Broedel’s NYRS retirement account to satisfy his loan was not               
          taxable income.  On the basis of the evidence before us, we hold            
          that petitioners realized $13,393.54.                                       


                                             Decision will be entered                 
                                        for respondent.                               
































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