Cir

Carlson v. Commissioner

Good Law
604 F. App'x 628
United States Court of Appeals for the Ninth CircuitMay 29, 201512-72030California382 words

Opinion

Opinion

MEMORANDUM

Karen Lee Carlson, appeals pro se from the Tax Court’s decision, following a bench trial, concerning her income tax liability for tax years 2001 through 2004. We have jurisdiction under 26 U.S.C. § 7482 (a)(1). We review de novo the Tax Court’s legal conclusions, and review for clear error its factual findings. Johanson v. Comm’r, 541 F.3d 973, 976 (9th Cir.2008). We affirm.

Contrary to Carlson’s contention, the Tax Court correctly concluded that Carlson had received taxable income, such as compensation for work performed for private companies, while she resided in Oregon and Washington. See 26 U.S.C. § 61 (a) (broadly defining “gross income” as “all income from whatever source derived, including (but not limited to) ... compensation for services”); id. § 62 (defining “adjusted gross income” as gross income less deductions and excluding “the performance of services by the taxpayer as an employee”' as a deduction); id. § 63 (defining “taxable income” as gross income less allowable deductions); United States v. Hanson, 2 F.3d 942, 945 (9th Cir.1993) (rejecting the argument that a natural born citizen of a state is not subject to the tax code), superseded on other…

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