Donald W. Wolgamott - Page 3

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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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