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are without merit and are groundless. Petitioners’ contentions
are patently absurd, based on mere semantics, and are unsupported
by the law. Petitioners’ assertions have been considered and
consistently rejected by this and other courts. See Eisner v.
Macomber, 252 U.S. 189, 207-208 (1920); United States v. Romero,
640 F.2d 1014, 1016 (9th Cir. 1981); Abrams v. Commissioner, 82
T.C. 403, 407-408 (1984), and cases cited therein; Rowlee v.
Commissioner, 80 T.C. 1111, 1119-1122 (1983); Bumgarner v.
Commissioner, T.C. Memo. 1997-48.
Gross income means all income from whatever source derived,
including (but not limited to) compensation for services. Sec.
61(a). Gross income includes income realized in any form,
whether in money, property, or services. Sec. 1.61-1(a), Income
Tax Regs. Income as defined under the 16th Amendment is “gain
derived from capital, from labor, or from both combined”. Eisner
v. Macomber, supra at 207. Even if wages could be characterized
as the product of an exchange, the amount received in the
exchange is still income within the Code. Rice v. Commissioner,
T.C. Memo. 1982-129. Although the wages received by petitioner
“may represent no more than the time-value of his work, they are
nonetheless the fruit of his labor, and therefore represent gain
derived from labor which may be taxed as income.” Id. Clearly,
the $50,847 petitioner received as compensation from his
employers during 1997 is taxable income.
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