What Is the Definition of Gross Income ?
The term "gross income" for federal income tax purposes is defined in I.R.C. 61(a)(1), which expressly provides that "gross income means all income from whatever source derived, including (but not limited to)...compensation for services, including fees, commissions...and similar items...."
Appellant's wages, compensation for services he provided as a non-employee, interest, dividends, and capital gains from stock transactions are "income" sources specifically listed in I.R.C. 61(a), thereby subjecting Appellant to liability for Minnesota taxable income. Minn. Stat. 290.01, subds. 19, 22, 29;
see Wallace v. Commissioner of Taxation, 289 Minn. 220, 225, 228, 184 N.W.2d 588, 593 (1971).
While there is no necessary tie between federal and Minnesota income tax, Minnesota exercised its discretion to use the federal return as the guide for calculating state tax pursuant to Minn. Stat. ch. 290 (2000).
Minn. Stat. 290.03 imposes, for each taxable year, "an annual tax...upon the taxable income for such year of ...resident...individuals...."
Minn. Stat. 290.01, subd. 19 (2000) provides that the Minnesota taxable net income of a resident individual, such as Appellant, is "federal taxable income as defined in Section 63 of the Internal Revenue Code of 1986...."
The Internal Revenue Code defines a taxpayer's taxable income as gross income less certain deductions not at issue in this case. 26 U.S.C. 62, 63.