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proof.3
A. Income From Kmart
Section 61 defines gross income as all income from whatever
source derived. Gross income includes compensation for services.
Sec. 61(a)(1).
In 1999, petitioner received $21,078.12 in wages from Kmart.
In motions, at trial, and on brief, petitioner advanced shopworn
arguments characteristic of tax protester rhetoric that has been
universally rejected by this and other courts. Wilcox v.
Commissioner, 848 F.2d 1007 (9th Cir. 1988), affg. T.C. Memo.
1987-225; Carter v. Commissioner, 784 F.2d 1006, 1009 (9th Cir.
1986). We shall not painstakingly address petitioner’s
assertions “with somber reasoning and copious citation of
precedent; to do so might suggest that these arguments have some
colorable merit.” Crain v. Commissioner, 737 F.2d 1417, 1417
(5th Cir. 1984).
B. Losses
Section 165(a) provides that there shall be allowed as a
deduction any loss sustained during the taxable year and not
compensated by insurance or otherwise. Section 165(c) limits the
loss deduction for individuals to losses incurred in a trade or
business, losses incurred in a transaction entered into for
profit, and certain casualty losses. Petitioner argues that he
3 We note, however, that our resolution of this issue does
not depend on which party bears the burden of proof.
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