- 4 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011