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Petitioner submitted to the Internal Revenue Service a Form
1040, U.S. Individual Income Tax Return, for 2001 listing only
zeros, e.g., listing zero income and zero tax due. Attached to
the Form 1040 was an affidavit from petitioner containing
frivolous and groundless arguments.
OPINION
I. Deficiencies
Section 61 defines gross income as all income from whatever
source derived. Gross income includes, among other things,
pensions and annuities. Sec. 61(a); see also sec. 72.
Petitioner admits that he received the income listed in the
notice of deficiency from the Defense Finance and Accounting
Service and from the TRW pension plan. Petitioner admits that
the amounts received from the Defense Finance and Accounting
Service were not amounts received as a pension or annuity for
personal injury or sickness resulting from active service in the
Armed Forces or as a disability annuity. See sec. 104(a)(4)
(excluding such amounts from income).
Accordingly, we conclude that the pension distributions
petitioner received during 2001 from the Defense Finance and
Accounting Service and from the TRW pension plan are includable
in income for 2001.
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Last modified: November 10, 2007