- 4 - 2002 and reflects $0.18 being deposited into the savings account on December 31, 2002. The Statement of Account also reports that petitioner’s checking account earned $12.99 of interest income in 2002. However, there is no evidence indicating whether that amount was ever deposited in or credited to the checking account. The IRS attempted to obtain information from Farmers with respect to the gross distribution that it reported for petitioner. As of the time of trial, the IRS had not obtained any additional information from Farmers as to this amount. Discussion Unemployment Compensation Under section 61(a)(1), “gross income” means all income from whatever source derived. The general rule of section 85 is that, “In the case of an individual, gross income includes unemployment compensation.” Sec. 85(a). “Unemployment compensation” means “any amount received under a law of the United States or of a State which is in the nature of unemployment compensation.” Sec. 85(b). Petitioner does not dispute that he received unemployment compensation during 2002. Petitioner argued at trial that he did not report the unemployment compensation because an IRS worksheet said that it was not taxable. Petitioner’s posttrial “clarification” memorandum argues that he did not report the unemployment compensation because his “income from the TexasPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011