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shifted to respondent. The Court cautioned petitioner at the
pretrial conference that if the Court did not sustain his posi-
tion as to the burden of proof and if he presented no evidence at
trial, he would lose this case. Despite the Court's warning,
petitioner chose not to present any evidence at trial or through
a stipulation of facts. Consequently, this case was submitted on
the basis of the record extant at the conclusion of the pretrial
conference.
The issues for decision are:
(1) Did petitioner have income for 1991 in the amount
determined by respondent in the notice, as reduced by the conces-
sion in respondent's memorandum brief? We hold that he did.
(2) Is petitioner liable for 1991 for self-employment tax?
We hold that he is.
(3) Is petitioner liable for 1991 for the addition to tax
under section 6651(a)(1)? We hold that he is.
(4) Is petitioner liable for 1991 for the addition to tax
under section 6654? We hold that he is.
(5) Is petitioner liable for a penalty under section 6673?
We hold that he is liable for a $5,000 penalty.
Petitioner resided in Carson City, Nevada, at the time he
filed the petition.
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