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Respondent’s Determination of
Year Petitioner’s Taxable Income
1999 $31,129
2000 73,650
2001 46,804
2002 42,171
Respondent treated petitioner as married filing separately,
allowed petitioner a standard deduction, and respondent
determined the tax deficiencies (which includes self-employment
taxes) and the additions to tax at issue herein.
OPINION
Section 61(a) defines gross income as “all income from
whatever source derived,” including earnings for services and
gross income derived from business. Sec. 61(a)(1) and (2).
Generally, taxpayers who receive income in a year equal to
or in excess of the exemption amount (i.e., $2,000 as adjusted
for inflation for 1999, 2000, 2001, and 2002) are required to
file Federal income tax returns. Secs. 151(d) and 6012(a)(1)(A),
(D)(ii).
Petitioner agrees that he received income in amounts of at
least $22,914, $45,073, $39,134, and $38,706 respectively for
1999, 2000, 2001, and 2002 (the amounts shown on the Forms 1099
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