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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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Last modified: May 25, 2011