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C. Petitioners’ Taxable Income
1. Terry I. Major’s Income
Terry contended that he did not receive any income as
defined in section 61 for the taxable year 2001, but he did not
offer any evidence supporting his position. Respondent, on the
other hand, provided documentation showing that Terry earned
income of at least $26,590.66 in 2001.
Terry’s online resume established that he was a computer
consultant for Major Computer Services. Ms. Yows confirmed: (1)
Terry furnished computer services for Dollarhide in 2001; (2)
Dollarhide paid Terry shortly after receiving invoices from him;
and (3) Dollarhide issued Terry a Form 1099-MISC for 2001.
Respondent also provided Forms 1099-MISC for both Dollarhide and
Lincoln for 2001. Terry offered no evidence or testimony
contesting respondent’s evidence. Terry had the opportunity to
cross-examine respondent’s two witnesses to attempt to elicit
favorable testimony, but he chose not to. The Court therefore
sustains the deficiency determined by respondent with respect to
Terry.
10(...continued)
tax system, the Code, and the Tax Court have been firmly
established as constitutional. Crain v. Commissioner, 737 F.2d
1417, 1417-1418 (5th Cir. 1984); Ginter v. Southern, 611 F.2d
1226, 1229 (8th Cir. 1979); Rev. Rul. 2005-19, 2005-14 I.R.B.
819.
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