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Section 1401 imposes taxes on the self-employment income of
every individual. Section 1402(b) defines self-employment income
as the net earnings from self-employment derived by an
individual. Section 1402(a) defines an individual's net earnings
from self-employment as the gross income derived by an individual
from any trade or business carried on by such individual, reduced
by income tax deductions attributable to the trade or business.
Petitioner bears the burden of proving that she is not liable for
additional taxes imposed by section 1401. Rule 142(a).
Petitioner does not dispute that she had additional self-
employment income during the year at issue. Therefore, we affirm
respondent's determination.
Issue 6. Negligence
Respondent determined that petitioner was liable for the
additions to tax for negligence under section 6653(a)(1) and (2).
Section 6653(a)(1) provides for an addition to tax of 5
percent of the underpayment if any part of the underpayment is
due to negligence or intentional disregard of rules or
regulations. Section 6653(a)(2) provides for an addition to tax
of 50 percent of the interest payable under section 6601 with
respect to the portion of the underpayment which is attributable
to negligence or intentional disregard of rules or regulations.
Negligence under section 6653(a) is a "'lack of due care or
failure to do what a reasonable and ordinarily prudent person
would do under the circumstances.'" Neely v. Commissioner, 85
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