- 3 - and the “possibility of a meltdown of software” at the Internal Revenue Service, he should not be required to pay taxes on the adjustments of income. Section 61 provides that all income, from whatever source derived, is includable in gross income unless specifically excluded by another provision. Compensation for services is specifically included in the definition of gross income. Sec. 61(a)(1). Unemployment compensation is includable in gross income. Sec. 85(a). Petitioner has not stated any disagreement with these basic rules established by statute. He has stipulated the amounts omitted from his tax return. His only argument with respect to his taxes for 1997 is that respondent’s computers sometimes make mistakes, so his return, as filed, is entitled to more credibility than the corrections set forth in respondent’s deficiency notice. Since petitioner does not dispute the accuracy of the corrections made in this case, his generalized objections to the accuracy of respondent’s computers as to other matters, whether true or not, are irrelevant to this case and without merit as objections to respondent’s determinations. In his oral argument, petitioner mentioned objections to the computation of amounts he owes to the Internal Revenue Service with respect to taxes for earlier years. Such matters are not relevant to our decision as to the amount at issue in these deficiency proceedings concerning petitioner’s tax for 1997 andPage: Previous 1 2 3 4 Next
Last modified: May 25, 2011