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received by petitioner during the years in issue are specified in
section 61, which provides in relevant part:
SEC. 61. GROSS INCOME DEFINED.
(a) General Definition.–-Except as otherwise
provided in this subtitle, gross income means all
income from whatever source derived, including (but not
limited to) the following items:
(1) Compensation for services, including
fees, commissions, fringe benefits, and similar
items;
* * * * * * *
(3) Gains derived from dealings in property;
(4) Interest;
* * * * * * *
(7) Dividends;
Petitioner’s arguments to the contrary have been consistently
rejected and characterized as frivolous in innumerable cases. No
further discussion of them is merited. See Crain v.
Commissioner, 737 F.2d 1417, 1418 (5th Cir. 1984); Cabirac v.
Commissioner, 120 T.C. 163, 167 (2003).
Petitioner stipulated that he had presented no evidence of
basis that would reduce the proceeds he received from the sale of
stock and that he offered no proof of any gambling losses that
would offset his gambling winnings. He has not suggested that he
had any deductions beyond the standard deduction allowed by
respondent in the statutory notice of deficiency.
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Last modified: May 25, 2011