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argument misconstrues the nature of an employee contribution,
however. The pension plans for NEBF and EWTF each prohibit
employee contributions. We are persuaded that no portion of the
pension disbursements at issue constituted the return of an
employee contribution and consequently sustain respondent's
determination.
B. Gambling Winnings
Respondent determined that the $1,000 lottery proceeds
received by petitioner in 2000 were includible in gross income as
gambling winnings. Lottery proceeds are gambling winnings,
taxable under section 61(a). See, e.g., Solomon v. Commissioner,
25 T.C. 936 (1956); Rusnak v. Commissioner, T.C. Memo. 1987-249.
Petitioner makes a series of arguments on brief concerning the
nature of "income" for Federal income tax purposes that do not
persuade us of any error in respondent's determination.
Accordingly, respondent's determination is sustained.
C. Social Security Benefits
Respondent determined that $11,501 of the $13,531 in Social
Security benefits received by petitioner in 2000 was includible
in his gross income for that year.7
7 On brief, respondent erroneously states that the
includible portion is the total amount of benefits received
($13,531) rather than 85 percent of that amount ($11,501) as
determined in the notice of deficiency. See sec. 86 (a)(2),
(c)(1) and (2).
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