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Rogers v. Commissioner, T.C. Memo. 2001-20 (quoting Crain v.
Commissioner, 737 F.2d 1417, 1418 (5th Cir. 1984)).
The first issue for decision is whether petitioner received
unreported income in the amounts determined by respondent. Gross
income generally includes income from whatever source derived,
including interest, gross income derived from business, and
income from discharge of indebtedness (DOI). See sec. 61(a)(2),
(4), (12). In addition to the tax imposed on income under
section 1, self-employment income is subject to a self-employment
income tax under section 1401. Self-employment income is defined
generally as the gross income, less certain allowable deductions,
derived by an individual from any trade or business carried on by
such individual. See sec. 1402(a) and (b).
As noted above, petitioner made no specific assertions of
error in the petition in this case. Furthermore, petitioner did
not refute respondent’s calculation of his tax liability for 1996
and 1997--specifically, respondent’s determination that
petitioner had unreported income in the stated amounts. On the
contrary, petitioner stipulated and the evidence reflects the
fact that he received from various sources payments of
approximately $129,000 in 1996 and $107,000 in 1997. Petitioner
refused to stipulate that he additionally received approximately
$32,000 in 1996 and $17,000 in 1997, not because he denied
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