- 5 - In December 2002, shortly before trial herein, there was issued to petitioner on behalf of Champion a Form W-2c, Corrected Wage and Tax Statement for 1998. At the same time, there was filed with respondent on behalf of Champion a Form W-3c, Transmittal of Corrected Wage and Tax Statements for 1998. Both statements reflected that, during 1998, Champion had paid wages to petitioner in the total amount of only $27,415. On December 27, 2002, petitioner filed with respondent his original 1998 individual Federal income tax return, which the accountant had prepared. On that return, petitioner reported total wages received in 1998 from Champion of only $27,415. Also on December 27, 2002, there was filed with respondent on behalf of Champion an amended 1998 corporate Federal income tax return for 1998, reflecting a $102,126 decrease in the deduction claimed for wages paid to petitioner.1 OPINION Taxable Wage Income Section 61(a) defines gross income as “all income from whatever source derived,” including compensation for services. The Supreme Court has held that gross income includes “undeniable accessions to wealth, clearly realized, and over which the 1 $129,541 (wage deduction claimed on Champion’s original 1998 corporate Federal income tax return) less $27,415 (wage deduction claimed on Champion’s amended 1998 corporate Federal income tax return) equals $102,126.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011