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the performing arts as an employee. Sec. 62(a)(2)(B). A
qualified performing artist is an individual: (1) Who performs
services in the performing arts for at least two employers during
the tax year and who receives at least $200 from each of two of
these employers; (2) whose related performing arts expenses are
more than 10 percent of such individual’s gross income from the
performance of those services; and (3) whose adjusted gross
income is not more than $16,000 before deducting those business
expenses. Sec. 62(b)(1) and (2). Respondent concedes that
petitioner meets requirements (1) and (2). The parties dispute
whether petitioner had “adjusted gross income” for purposes of
section 62(b)(1)(C) of more than $16,000 in 2000.
2. Petitioner’s Contentions Regarding the Statutory
Language
Petitioner contends that the term “adjusted gross income” in
section 62(b)(1)(C) includes only petitioner’s gross income from
acting activities, not his gross income from all sources. We
disagree. “Adjusted gross income” is, in the case of an
individual, gross income minus certain deductions. Sec.
62(a)(1).4 Gross income includes all income from whatever source
4 Sec. 62 provides, in pertinent part:
SEC. 62. ADJUSTED GROSS INCOME DEFINED.
(a) General Rule.--For purposes of this subtitle,
the term “adjusted gross income” means, in the case of
an individual, gross income minus the following
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