- 4 - for each year plus additions to tax under sections 6651(f) and 6654. Petitioner timely filed his petition seeking a redetermination. On August 7, 2003, in the U.S. District Court for the Southern District of Ohio, petitioner pleaded nolo contendere to four counts under section 7203 of willfully failing to file Federal income tax returns for 1994, 1995, 1996, and 1997. Petitioner was sentenced to four 2-year terms of probation to be served concurrently and ordered to pay a fine of $2,000 and restitution of $27,475.97 in respect of his income tax liabilities for 1994, 1995, 1996, and 1997. OPINION I. Unreported Income Pursuant to section 61(a), gross income includes “all income from whatever source derived”. Section 61(a)(1) provides that gross income includes compensation received in exchange for services rendered. With respect to such income it is well settled that the person who earns income is taxed on the income. Commissioner v. Culbertson, 337 U.S. 733, 739-740 (1949). Generally, a sole proprietor who derives income from a trade or business is considered to have received self-employment income. Secs. 1.1401-1(c), 1.1402(c)-1, Income Tax Regs. Self-employed individuals are also liable for self-employment tax pursuant to section 1401 as part of their Federal income tax liability. SeePage: Previous 1 2 3 4 5 6 7 8 9 10 Next
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