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Office * * * or from the D.C. Government.” Petitioner conceded
that he received the unemployment compensation checks, but
claimed he was unsure whether they were for 1998 or 1999.
OPINION
Section 61 provides that all income, from whatever source
derived, is includable in gross income unless specifically
excluded by another provision. See Commissioner v. Glenshaw
Glass Co., 348 U.S. 426, 431 (1955). “In the case of an
individual, gross income includes unemployment compensation.”
Sec. 85(a). “[T]he term ‘unemployment compensation’ means any
amount received under a law of the United States or of a State
which is in the nature of unemployment compensation.” Sec.
85(b). “The amount of any item of gross income shall be included
in the gross income for the taxable year in which received by the
taxpayer”. Sec. 451(a). Petitioner has not stated any
disagreement with these basic rules.
Petitioner testified that he did not report his unemployment
compensation for 1998 because he was unsure of what year the
unemployment compensation checks were for. Yet, he admitted at
trial that he received and endorsed the checks issued to him by
the DCDES during 1998. Based on the record we find that
petitioner did receive $4,017 in unemployment compensation from
the DCDES in 1998.
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