- 6 - OPINION I. Petitioner’s Protester Arguments Petitioner has asserted frivolous arguments to support his contention that he did not have to pay Federal income taxes for the 1999 tax year. To educate petitioner, we shall briefly address his arguments. A. Petitioner Received Income Petitioner argues that he did not receive “income” in 1999. This argument relies on petitioner’s assertion that the Internal Revenue Code does not define the term “income”. This Court has consistently rejected this argument. Section 61(a) defines gross income to include “income from whatever source derived”. More specifically, section 61(a) includes in an individual’s gross income any compensation for services, interest payments, dividend payments, and gains derived from dealings in property. Clearly, petitioner’s compensation from PFS, interest payments from banks where he maintained accounts, and dividend payments from corporations in which he held stock are gross income for Federal income tax purposes. See Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955) (stating that gross income includes all accessions to wealth that are clearly realized and under the control of the taxpayer); Grimes v. Commissioner, 82 T.C. 235, 237 (1984); Reiff v. Commissioner, 77 T.C. 1169, 1173 (1981). Additionally,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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