- 6 -
Unreported Income
Gross income includes all income from whatever source
derived. Sec. 61(a). Section 61(a)(1) specifically includes
income derived from compensation for services, including fees,
commissions, fringe benefits, and similar items. It is required
under Federal law that taxpayers maintain adequate and accurate
tax records. Sec. 6001; see also Jones v. Commissioner, 903 F.2d
1301, 1303 (10th Cir. 1990), affg. in part, revg. in part and
remanding T.C. Memo. 1988-373.
Petitioner does not dispute that he received $24,000 from
QSN during 1997 in addition to his regular salary. Petitioner
instead argues that respondent mischaracterized the checks as
commission checks, rather than reimbursements for other business
expenses; namely, out-of-pocket expenditures from business
dealings in Mexico with QSN’s client, McCulloch.
The record consists of petitioner’s weekly expense reports
and currency exchange worksheets that he submitted to QSN’s
headquarters for reimbursements in 1997. We find it puzzling
that petitioner failed to produce credit card statements,
receipts, expense records or logs, additional currency exchange
reports, independent testimony, or any other credible evidence to
2(...continued)
penalty, we find that respondent has satisfied his burden of
production under sec. 7491(c) because the record shows that
petitioner failed to include the income on his return. Higbee v.
Commissioner, 116 T.C. 438 (2001).
Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011