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A. Unreported Income
Gross income includes all income from whatever source
derived, specifically including gross income derived from
business, gains derived from dealings in property, and rents.
Sec. 61(a)(2), (3), (5).
Petitioner admittedly concedes by way of the stipulation of
facts and his own testimony that he received unreported income in
excess of the adjustments in the notice of deficiency.
Specifically, petitioner admitted that he received unreported
gross receipts or sales of $1,891 and rental income in the
aggregate amount of $9,112.
With respect to the amount of rental income, we note that
petitioner conceded the adjustments in the notice of deficiency
in the amounts of $2,380 and $642. The first amount is
consistent with the amount of rental income reported on
petitioner’s revised Form 1040 for the Yellow Wood property. The
latter amount of $642 appears to be included in the total rental
income amount of the other 2 properties. Therefore, we limit the
amount of unreported rental income to $6,090 (i.e., $3,960 +
$2,772 - $642).
Accordingly, we conclude that petitioner received unreported
gross receipts or sales of $1,891 and unreported rental income of
$6,090 in excess of that determined by respondent in the notice
of deficiency.
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Last modified: May 25, 2011