- 11 -
B. Discussion
1. Stipulated and Reported Items
Section 61(a) provides that gross income means income from
whatever source derived. Among the items of gross income
specifically enumerated in section 61(a) are compensation for
services, interest, dividends, pensions, and gains derived from
business and from dealings in property. The wages, social
security payments, pension payments, interest, dividends,
reported gross income from consulting, and rents and royalties
set forth in our findings of fact supra, which either have been
stipulated by the parties to be taxable or were set forth on the
Nov. 10 return, are all items of gross income for 2000 in the
amounts specified.
2. Schedule D Items
a. Agreements and Disagreements
The parties agree that, on account of the sales of his
interests in Ford and Citigroup reported on the Schedule D,
petitioner realized gains of $19 and $7, respectively. While the
parties agree that petitioner made the sales of his interests in
Oxford and Kemper reported on the Schedule D, and that he
realized gains on account of those sales, they disagree on the
amounts of those gains. As we have found, with respect to
Oxford, petitioner reported on the Schedule D proceeds of $3,406,
cost or other basis of $2,962, and a resulting gain of $444; with
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011