- 82 - 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 realizedPage: Previous 72 73 74 75 76 77 78 79 80 81 82 83 84 85 86 87 88 89 90 91 Next
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