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as net earnings from self-employment derived by an individual.
The term "net earnings from self-employment" means gross income
derived by an individual from any trade or business carried on by
such individual, less the deductions allowed by the Code that are
attributable to such trade or business, plus certain items not
relevant here. Sec. 1402(a). The term "trade or business", for
purposes of the self-employment tax, generally has the same
meaning as it has for purposes of section 162. Sec. 1402(c).
Petitioners contend that assuming arguendo that we were to
sustain respondent's positions that petitioners have unreported
income for 1989 and 1990 resulting from the deposits of K & H's
and Ms. Velilla's funds and for 1990 resulting from the discharge
of the outstanding balances of the Kabeiseman loans, such income
would not be subject to self-employment tax. According to peti-
tioners, any such income does not constitute self-employment in-
come because it is not gross income derived from a trade or busi-
ness carried on by petitioner. Since we have found that peti-
tioners do not have unreported income for 1990 resulting from the
discharge of the outstanding balances of the Kabeiseman loans, we
shall address petitioners' contention regarding respondent's de-
terminations of self-employment tax for the years at issue only
insofar as that contention relates to our findings that petition-
ers have unreported income for 1989 and 1990 resulting from the
deposits of K & H's and Ms. Velilla's funds. Respondent does not
address that issue in her opening brief, nor does she respond to
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