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3, 1985. Petitioner received rents of $1,250 from Crazy
Commandos in 1985.
Petitioner received $400 in 1985 from the sale of 100 wax
myrtle trees.
OPINION
Gross income means all income from whatever source derived,
including compensation for services, commissions, gross income
derived from business, gains derived from dealings in property,
rents, etc. Sec. 61(a). Petitioner does not contest
respondent’s determinations in the notice of deficiency, his
requested findings of fact, or his arguments on brief with
respect to the amounts that petitioner received. Petitioner has
abandoned any arguments he may have made with respect to those
amounts. We hold that petitioner is taxable for the various
amounts described above as determined by respondent.
D. Schedule E Income
FINDINGS OF FACT
Petitioner owned stock in Frank’s Corner, Inc., an S
corporation. Frank’s Corner filed a Schedule K-1 (Form 1120S),
Shareholder’s Share of Income, Credits, Deductions, etc.,
relating to petitioner for 1987. The Schedule K-1 reported
ordinary income of $4,492 and a section 179 deduction of $604.
Petitioner did not report any income from Frank’s Corner on his
1987 return. Respondent determined that petitioner realized
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