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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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