Timothy Demitri Brown - Page 9

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          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.            

















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