Richard Clarke Randall - Page 4

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          allege a payment to the party identified as the ‘RECIPIENT’ of              
          ‘gains, profit or income’ made in the course of a ‘trade or                 
          business’” and that he had “rebutted both of these documents in             
          attachments” to his amended 2003 return.                                    
               Section 61 provides that “gross income means all income                
          from whatever source derived.”  Gross income is an inclusive term           
          with broad scope, designed by Congress to “exert * * * ‘the full            
          measure of its taxing power’”.  Commissioner v. Glenshaw Glass              
          Co., 348 U.S. 426, 429 (1955) (quoting Helvering v. Clifford, 309           
          U.S. 331, 334 (1940)).   Compensation for services is enumerated            
          among the items of income included under section 61.  Sec.                  
               Petitioner agrees that he has in fact received the amounts             
          reportedly paid to him; he simply argues that the amounts are not           
          taxable.  Petitioner’s argument is clearly without merit, and we            
          hold that the amounts of nonemployee compensation received by               
          petitioner are includible in his taxable income for 2003.                   
               Respondent also determined that petitioner is liable for an            
          accuracy-related penalty under section 6662(a).  In relevant                
          part, section 6662(a) and (b) imposes an accuracy-related penalty           
          if any portion of an underpayment is attributable to either (1)             
          negligence or disregard of rules or regulations or (2) any                  
          substantial understatement of income tax.  “Negligence” includes            

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