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of the tribal council was reflected as “other income”, and the
$33,295 relating to petitioner’s work as secretary or executive
assistant to the tribal president was reflected as “nonemployee
compensation”.
Petitioner electronically and timely filed with respondent
her 2001 individual Federal income tax return, on which
petitioner reflected zero tax liability. Thereon, petitioner did
not include as income the $57,845 she received from the tribe.
On October 14, 2003, respondent mailed to petitioner a
notice of deficiency with regard to petitioner’s 2001 tax
liability in which respondent determined that the entire $57,845
petitioner received in 2001 from the tribe constituted taxable
income, that the $33,295 petitioner received from the tribe for
her work as secretary or executive assistant constituted self-
employment income on which petitioner was liable for self-
employment tax, and that petitioner was liable for the section
6662(a) accuracy-related penalty with respect to the income and
self-employment tax underpayments relating to the $57,845 not
reported as income and the $33,295 not reported as self-
employment income.
OPINION
Section 61(a) defines gross income as “all income from
whatever source derived,” including compensation for services.
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Last modified: May 25, 2011