David G. Turner - Page 6

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                                       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,                     






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