-5-
the Court that respondent’s determination is incorrect. Id. at
446-447.
B. Unreported Amounts
The definition of gross income under section 61(a) broadly
encompasses any accession to a taxpayer’s wealth. United States
v. Burke, 504 U.S. 229 (1992); Commissioner v. Glenshaw Glass
Co., 348 U.S. 426, 431 (1955). Compensation for services and
interest are specifically included within that definition. Sec.
61(a)(1), (4). We conclude that the unreported amounts are
includable in petitioner’s gross income and are taxable as such.
C. Self-Employment Tax
Section 1401 imposes a tax on the self-employment income of
every individual for old age, survivors, and disability
insurance, and hospital insurance. Sec. 1401(a) and (b);
Schelble v. Commissioner, 130 F.3d 1388, 1391 (10th Cir. 1997),
affg. T.C. Memo. 1996-269; sec. 1.1401-1(a), Income Tax Regs.
Self-employment income includes the net earnings from
self-employment derived by an individual during the taxable year.
Sec. 1402(b). In this context, the term “net earnings from
self-employment” denotes the gross income derived by an
individual from any trade or business carried on by the
individual, reduced by, inter alia, the deductions attributable
to the trade or business. Sec. 1402(a); sec. 1.1402(a)-1, Income
Tax Regs.
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