Walter L. Medlin - Page 157

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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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