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proposed adjustments. Respondent mailed a notice of deficiency
to petitioner on September 28, 2001.
Petitioner had no Federal income taxes withheld from his
wages for the taxable years 1997 and 1998. He made no estimated
tax payments for those years.
OPINION
A. Taxable Income Determinations
Gross income means all income from whatever source derived.
Sec. 61(a). It is beyond contention that wages represent taxable
income. See sec. 61(a)(1); United States v. Connor, 898 F.2d
942, 943 (3d Cir. 1990); Grimes v. Commissioner, 82 T.C. 235, 237
(1984). It is also clear that interest, pension and IRA
distributions are taxable as income. Secs. 61(a)(4), (11),
408(d)(1).
Respondent determined that petitioner received taxable
wages, interest, and pension and IRA distributions in 1997 and
1998. Petitioner stipulated that he received the amounts
determined by respondent as income. However, he argues that the
income tax is an excise tax and that he did not engage in taxable
excise activities during the taxable years in question. We have
previously rejected petitioner’s argument as frivolous, and we
see no need to address petitioner’s argument with any further
discussion. Sawukaytis v. Commissioner, T.C. Memo. 2002-156;
Heisey v. Commissioner, T.C. Memo. 2002-41, affd. ___ Fed. Appx.
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