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2. Unreported Wage Income
As previously stated, respondent determined that petitioner
did not file a Federal income tax return for the taxable year
1997, and did not report wage income of $33,711 received during
that year. Petitioner, however, contends that her husband
purportedly filed a joint return “on their behalf” in 1997, and
that the wage income at issue was reported on that return.
Therefore, she argues, she has no present liability for tax
stemming from her unreported wage income received in 1997.
Section 61(a) defines gross income as “all income from
whatever source derived, including * * * (1) Compensation for
services” unless otherwise provided. Moreover, section 6001
requires any person liable for tax imposed under title 26 to keep
records, render statements, make returns, and comply with the
rules and regulations.
In this case, petitioner admitted at trial that she did, in
fact, receive wage income in 1997 in the amount of $33,711, from
her work as a dance instructor. However, she also testified that
she kept no records of receiving these wages and filed no
separate return for that year. Petitioner nevertheless contests
respondent’s determination of her liability on the grounds that
she and Mr. Conner had agreed to file a joint return for 1997 to
include this income, and that irrespective of whether or not a
joint return was filed, she could not have filed separately for
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Last modified: November 10, 2007