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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 and
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Last modified: May 25, 2011