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B. Petitioner’s Tax Liabilities
Section 1(c) imposes a tax on the taxable income of
unmarried individuals. Section 63(b) defines “taxable income”,
as applicable to petitioner’s situation, as gross income less the
standard deduction and one personal exemption. Section 61(a)
defines gross income to mean “all income from whatever source
derived”, specifically including compensation for services and
interest. Sec. 61(a)(1), (4). Given the broad phraseology of
section 61(a), courts have consistently held that gambling
winnings are also includable in gross income. See, e.g.,
Lyszkowski v. Commissioner, T.C. Memo. 1995-235, and cases cited
therein, affd. without published opinion 79 F.3d 1138 (3rd Cir.
1996).
As detailed above, petitioner's taxable income for the years
in issue is as follows:
1995 1996 1997
Compensation $45,282 $63,640 $61,825
Interest income 5 82 27
Gambling winnings –-- 9,867 –--
Gross income 45,287 73,589 61,852
Less:
Personal exemption -2,500 -2,550 -2,650
Standard deduction -3,900 -4,000 -4,150
Taxable income 38,887 67,039 55,052
Pursuant to section 1(c), petitioner’s tax liabilities for
the years in issue are as follows:
1995 1996 1997
$7,852 $15,917 $12,210
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