Harvey L. Hoover - Page 25

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          regarding petitioner’s 1989 tax year, we hold that assessment of            
          any deficiency regarding 1989 is barred by the 3-year period of             
          limitations contained in section 6501(a).                                   
          III.  1990, 1991, and 1992                                                  
               Respondent argues that petitioner failed to report farm                
          income of $173,663.38 in 1990, $121,595.51 in 1991, and                     
          $119,393.46 in 1992.14  Generally, petitioner argues that                   
          respondent committed injustice against him in this case.15                  
          Petitioner asserts that he did not receive the income respondent            
          determined, and that he incurred farm expenses that exceeded the            
          amounts respondent allowed.  Finally, petitioner contends that              
          his assets were sold in the divorce proceeding and that he lost             
          $156,000 from the sale of his assets.                                       
               A.   Unreported Gross Income                                           
               Section 61(a) provides that “gross income means all income             
          from whatever source derived,” and specifically includes “Gross             
          income derived from business”.  Section 6001 requires that                  
          taxpayers maintain books and records sufficient to establish                

               14 These amounts include both ordinary farm income and                 
          capital gains income.  Respondent asserts that petitioner’s                 
          capital losses will offset the capital gains income, and the                
          capital gains income will not result in additional tax.                     
               15 Petitioner asserts that he did not receive the income               
          determined by respondent, and warns:  “I have been taxed on                 
          Income I didn’t receive and will never receive.  If something is            
          not done I will go public with this including congress, senators,           
          Television, Newspapers.”                                                    

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