- 6 - Unreported Income A taxpayer’s gross income includes all income from whatever source derived, including (but not limited to) compensation for services, gains derived from dealings in property, interest, and dividends.6 Sec. 61(a)(1), (3), (4), (7). In the present case, petitioner received wages of $1,972, dividends of $1,561, interest of $1,643, a gain of $12,554.87 from the sale of Peco stock, and a loss of $131.75 from the sale of Americo stock. Accordingly, petitioner’s gross income for the 2000 taxable year is $17,599.12. We sustain respondent’s determination on this issue to the extent of this amount. Addition to Tax Under Section 6651(a)(1) If a Federal income tax return is not timely filed, an addition to tax will be assessed “unless it is shown that such failure is due to reasonable cause and not due to willful neglect”. Sec. 6651(a)(1). A delay is due to reasonable cause if “the taxpayer exercised ordinary business care and prudence 6 A taxpayer’s gross income also includes a refund of State income tax in the year received to the extent that said tax was claimed as a deduction in any prior taxable year and resulted in a reduction in Federal income tax. See sec. 111(a); Kadunc v. Commissioner, T.C. Memo. 1997-92. While the record indicates that petitioner received in 2000 an income tax refund of $114 from the Commonwealth of Virginia Department of Tax, said amount was not included in petitioner’s gross income as part of respondent’s determination, and respondent did not raise this matter at any time after the issuance of the notice of deficiency. Accordingly, we do not address whether the State income tax refund was includable in petitioner’s gross income for the 2000 taxable year.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011