- 8 - in the answer. The change was based on respondent’s decision to rely on an amount from the lower end of a range of values purportedly supported by the testimony given at petitioner’s criminal trial. Petitioner filed a response to respondent’s proposed findings and memorandum. In this document, petitioner again attacked his criminal conviction and the testimony given at the criminal trial and largely repeated or augmented many of the contentions made in previous filings. Additionally, in response to allegations by respondent that petitioner deposited cash into his personal bank account of $21,000 in 1990 and $24,000 in 1991, petitioner admitted cash deposits were made but claimed, without any documentary support, that the funds represented loans from Hatcher. Discussion I. Unreported Income The Internal Revenue Code imposes a Federal tax on the taxable income of every individual. Sec. 1. Section 61(a) defines gross income for purposes of calculating taxable income as “all income from whatever source derived”. This broad definition includes income obtained from illegal sources. James v. United States, 366 U.S. 213, 218 (1961); sec. 1.61-14(a), Income Tax Regs. Respondent has determined that petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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