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1. Receipt of Wage Income
Petitioner does not dispute that he received $34,840 from
TIAA-CREF, by whom he was employed. Petitioner argues that his
wages do not constitute income or that he is exempt from income.
Section 61(a) defines gross income as “all income from
whatever source derived,” unless otherwise provided. The Supreme
Court has consistently given this definition of gross income a
liberal construction “in recognition of the intention of Congress
to tax all gains except those specifically exempted.”
Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 430 (1955); see
also Roemer v. Commissioner, 716 F.2d 693, 696 (9th Cir. 1983)
(all realized accessions to wealth are presumed to be taxable
income, unless the taxpayer can demonstrate that an acquisition
is specifically exempted from taxation), revg. 79 T.C. 398
(1982). Suffice it to say that petitioner is a taxpayer who is
subject to Federal income tax on his wages and other sources of
income. See secs. 1(c), 61(a)(1), (11), 7701(a)(1), (14); Nestor
v. Commissioner, 118 T.C. 162, 165 (2002), supplemented by T.C.
Memo. 2002-251. Petitioner presented this Court with frivolous
contentions that merit no discussion. See Rowlee v.
Commissioner, 80 T.C. 1111 (1983); Hallock v. Commissioner, T.C.
Memo. 1983-684. Thus, we sustain respondent’s determination that
petitioner’s wages constitute gross income.
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