                       T.C. Memo. 2001-188



                     UNITED STATES TAX COURT



               DONALD W. WOLGAMOTT, Petitioner v.
          COMMISSIONER OF INTERNAL REVENUE, Respondent



     Docket No. 3320-00.                       Filed July 24, 2001.



     Donald W. Wolgamott, pro se.

     Julie L. Payne, for respondent.



                       MEMORANDUM OPINION

     WOLFE, Special Trial Judge:    Respondent determined a

deficiency in petitioner’s Federal income tax of $2,982 for

1997.1

     Some of the facts have been stipulated and are so found,



     1
      Unless otherwise indicated, subsequent section references
are to the Internal Revenue Code in effect for the year in issue.
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except as noted below.    Petitioner resided in Seattle,

Washington, on the date the petition was filed in this case.

     During 1997, petitioner received $10,186 from the State of

Washington as deferred compensation.    Petitioner failed to report

any of this amount on his 1997 Federal income tax return.    In

1997, petitioner also received $3,072 from the State of

Washington Employment Security Department as unemployment

compensation.   Petitioner reported only $2,608 of unemployment

compensation on his 1997 Federal income tax return.2   On his tax

return, petitioner also understated the amount of wages withheld

by $305.

     Respondent’s adjustments increase petitioner’s wage income

by $10,186, and his unemployment compensation by $464, and

increase the amount of tax withholding by $305.    The deficiency

notice determines an increase in tax of $2,982 and states that

because of the increase to withholding petitioner owes additional

tax of $2,677 for 1997.

     Petitioner argues that because of “major computer problems”



     2
      The parties stipulated that during 1997, petitioner
received unemployment compensation of $3,072, and that none of it
was reported on his Federal income tax return for 1997.
Actually, petitioner reported $2,608 of unemployment compensation
for 1997, and respondent seeks an adjustment to the amount of
unemployment compensation of only $464 (the difference between
$2,608 and $3,072). Since the stipulation is clearly contrary to
facts disclosed in the record to the extent of this mechanical
error, we are not bound by the stipulation. Jasionowski v.
Commissioner, 66 T.C. 312, 318 (1976).
                                 - 3 -

and the “possibility of a meltdown of software” at the Internal

Revenue Service, he should not be required to pay taxes on the

adjustments of income.

     Section 61 provides that all income, from whatever source

derived, is includable in gross income unless specifically

excluded by another provision.    Compensation for services is

specifically included in the definition of gross income.     Sec.

61(a)(1).   Unemployment compensation is includable in gross

income.   Sec. 85(a).   Petitioner has not stated any disagreement

with these basic rules established by statute.    He has stipulated

the amounts omitted from his tax return.    His only argument with

respect to his taxes for 1997 is that respondent’s computers

sometimes make mistakes, so his return, as filed, is entitled to

more credibility than the corrections set forth in respondent’s

deficiency notice.   Since petitioner does not dispute the

accuracy of the corrections made in this case, his generalized

objections to the accuracy of respondent’s computers as to other

matters, whether true or not, are irrelevant to this case and

without merit as objections to respondent’s determinations.

     In his oral argument, petitioner mentioned objections to the

computation of amounts he owes to the Internal Revenue Service

with respect to taxes for earlier years.    Such matters are not

relevant to our decision as to the amount at issue in these

deficiency proceedings concerning petitioner’s tax for 1997 and
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in any other respect are not before this Court in these

proceedings.

     Accordingly, we conclude that petitioner is liable for the

deficiency determined by respondent.

     To reflect the foregoing,

                                              Decision will be entered

                                         for respondent.
