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FLEISCHLI v. COMMISSIONER

Docket No. 5766-03.

123 T.C. 59 (2004)

123 T.C. No. 3

JACK A. FLEISCHLI, A.K.A. JACK FORBES, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 14, 2004.

Attorney(s) appearing for the Case

Jack A. Fleischli, pro se.

John D. Faucher, for respondent.

COLVIN, Judge:

Respondent determined a deficiency in petitioner's 2000 Federal income tax of $5,580 and an accuracy-related penalty under section 6662(a)1 of $1,116. Respondent concedes that petitioner is not liable for the section 6662(a) penalty.

After concessions, the issue for decision is whether, for purposes of section 62(b)(1)(C), "adjusted gross income" includes only a taxpayer's income from the performance of services...

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