Glory Allen - Page 4

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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             
               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.                                                          

               Section 61(a) defines gross income as “all income from                 
          whatever source derived,” including compensation for services.              

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