- 9 - Self-employment income generally consists of the gross income derived by an individual from any trade or business, less allowable deductions. Sec. 1402(a) and (b). Mr. Brown bears the burden of proving that he is not liable for the self-employment tax. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Mr. Brown reported net taxable income from his business in 1993 and offered no proof that such income is not subject to the self- employment tax. We, therefore, sustain respondent’s determination that Mr. Brown is liable for the self-employment tax for the taxable year 1993. Decision will be entered for respondent with respect to the deficiency. Decision will be entered for petitioner with respect to the accuracy-related penalty.Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011