Greg Olson - Page 8

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          The scope of this definition is broad, typically reaching any               
          accretions to wealth.  Commissioner v. Schleier, 515 U.S. 323,              
          327 (1995); Commissioner v. Glenshaw Glass Co., 348 U.S. 426,               
          429-431 (1955).  Among the items expressly classified as income             
          under section 61(a) is “Compensation for services, including                
          fees, commissions, fringe benefits, and similar items”.  Sec.               
               Petitioner conceded in signed stipulations that he received            
          wage income during 1999 and 2000 in the amounts of $18,521, and             
          $16,719, respectively.  He similarly admitted that he received              
          nonemployee compensation of $8,122 in 1999 and $17,181 in 2000.             
          As previously indicated, petitioner’s arguments as to why this              
          income is nontaxable are meritless.  The Court concludes that               
          petitioner is liable for income tax deficiencies on the above               
          compensation.  Similarly, given petitioner’s concession that the            
          $8,122 and $17,181 amounts constitute nonemployee compensations,            
          these amounts are subject to self-employment tax under section              
               B.  Additions to Tax                                                   
               Section 7491(c) places on the Commissioner the burden of               
          production regarding additions to tax.  The burden with respect             
          to “reasonable cause, substantial authority, or similar                     
          provisions” then shifts to the taxpayer.  Higbee v. Commissioner,           

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