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“exempt” from withholding, he has no tax liability for salaries
received of $25,851 and $25,732 during taxable years 2001 and
2002, respectively. Petitioner further contends that no section
of the Internal Revenue Code establishes an income tax liability
or provides that income taxes have to be paid on the basis of a
return and that he had “zero” income according to the Supreme
Court’s definition of income.
Section 61(a) defines gross income as “all income from
whatever source derived,” unless otherwise provided. The Supreme
Court has consistently given this definition of gross income a
liberal construction “in recognition of the intention of Congress
to tax all gains except those specifically exempted.”
Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 430 (1955); see
also Roemer v. Commissioner, 716 F.2d 693, 696 (9th Cir. 1983)
(all realized accessions to wealth are presumed taxable income,
unless the taxpayer can demonstrate that an acquisition is
specifically exempted from taxation), revg. 79 T.C. 398 (1982).
It is beyond contention that wages represent gross income. See
sec. 61(a)(1); United States v. Connor, 898 F.2d 942, 943 (3d
Cir. 1990); Grimes v. Commissioner, 82 T.C. 235, 237 (1984).
Petitioner has failed to provide any evidence to disprove
respondent’s determinations. He simply presented this Court with
frivolous contentions that merit no discussion. See Rowlee v.
Commissioner, 80 T.C. 1111 (1983); Hallock v. Commissioner, T.C.
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