- 8 - “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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011