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§2.2 GROSS INCOMEvictim as a punishment to the wrongdoer—are also not the result of some profitableendeavor of labor or capital.An item of income is considered, for tax purposes, to first be an item of grossincome.The federal tax law contemplates, in addition to the generation of grossincome, persons who are the recipients of the income and who will pay a tax onit. These persons generally are:• Individuals• Corporations• Trusts• EstatesThe ways of determining gross income and the rates for taxing it differ, but thesepersons are taxpayers: those human beings and entities, the latter recognized inthe law (fictionally) as persons, that are obligated to pay the federal income tax.§ 2.2 GROSS INCOMEThe term gross income is defined in the Internal Revenue Code as “all incomefrom whatever source derived.” 2 The statutory definition of gross income isbroadly defined by the Supreme Court to include all “undeniable accessions towealth, clearly realized, and over which the taxpayer has complete dominion.” 3The Court made it clear in this opinion that these accessions to wealth areincome regardless of their source, and regardless of any attached label as to itsnature. Under this broad definition, a gain (accession to wealth) that is clearlyrealized, regardless of label or source, is gross income.Gross income includes, among other items:• Alimony• Annuities• Bartering income• Business income• Cancellation of indebtedness• Dividends• Gains• Gambling winnings• Interest• Pensions and annuities• Prizes and awards• Rental income• Royalties• Wages, salaries, and gratuities2 IRC § 61(a).3 Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955). 29