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SEC. 61. GROSS INCOME DEFINED.
(a) General Definition.--Except as
otherwise provided in this subtitle,
[subtitle A, relating to income taxes] gross
income means all income from whatever source
derived, including (but not limited to) the
following items:
(1) Compensation for services, including
fees, commissions, fringe benefits, and similar
items;
(2) Gross income derived from business;
(3) Gains derived from dealings in property;
(4) Interest;
(5) Rents;
(6) Royalties;
(7) Dividends;
(8) Alimony and separate maintenance
payments;
(9) Annuities;
(10) Income from life insurance and endowment
contracts;
(11) Pensions;
(12) Income from discharge of indebtedness;
(13) Distributive share of partnership gross
income;
(14) Income in respect of a decedent; and
(15) Income from an interest in an estate or
trust.
(b) Cross References.--
For items specifically included in gross
income, see part II (sec. 71 and following). For
4(...continued)
(2) the sections 1 and 55 taxes as limited by section 1211(b)
constitute direct taxes that must be apportioned; and (3) full
deductibility of capital losses is the preferred way to save the
entire income tax from invalidation.
Because we hold that petitioners have failed to persuade us
as to the first of these three items, we do not explore the
second and third items.
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Last modified: May 25, 2011