Brett Alan Combs - Page 4

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          standard deduction (which exceeds the itemized deductions                   
          substantiated by petitioner), and a deduction for half of his               
          self-employment taxes.                                                      
                                     Discussion                                       
          Section 861                                                                 
               Petitioner’s first and, apparently, primary argument                   
          concerns his “confusion” about the “requirements” of section 861,           
          Income From Sources Within the United States.  According to                 
          petitioner, in a West publication that he read, section 61 cross            
          referenced section 861, and he is therefore “required” to                   
          consider it.  While the Court suspects that petitioner’s                    
          “confusion” is disingenuous, the Court will, for his present and            
          future benefit, explain the operation of section 861.                       
               It seems strange that petitioner feels compelled to delve              
          into the intricacies of section 861 as that section, along with             
          those immediately following, are aimed at the U.S. income tax               
          effects of international activities.  Section 861(a) provides a             
          rule for determining whether items of gross income are from                 
          sources within the United States (U.S. source).  Section 862                
          provides the sourcing rules for items of gross income from                  
          sources without the United States (foreign source).  Under                  
          section 863, items of gross income, expenses, losses and                    
          deductions other than those specified in sections 861 and 862               






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