Elliot Virgil Wilkerson - Page 10

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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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