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" ... Naturally, the memorandum noted that gross income under section 61 includes income from whatever source derived, which includes compensation for services. Using the familiar Glenshaw Glass framework, gross income includes “undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion.”[1] Moreover, under section 83, generally the value of property exchanged for the performances of services is included in the income of the service provider. ... "
" ... Those general principles include the fundamental general rule under section 61 of the Internal Revenue Code: Gross income includes all income from whatever source derived. The concept of gross income, as used in section 61, has a broad scope indeed. As the Supreme Court held more than a half century ago in the seminal case of Commissioner v. Glenshaw Glass Co., 348 U.S. 426, 431 (1955), it generally includes all gains or accessions to wealth, clearly realized, and over which a taxpayer has complete dominion. ... "