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Self-employment Tax
Respondent determined that the income that petitioner
received from JMS during 1992 is self-employment income and that
petitioners are liable for self-employment tax on that income
under sections 1401 and 1402. Except for the amount of compensa-
tion that petitioner received from JMS during 1992, petitioners
do not contest respondent's determination under sections 1401 and
1402.
On the record before us, we find that petitioners are liable
for 1992 for self-employment tax on $9,100 of income from JMS
that they did not report in their 1992 return.
Section 6651(a)(1)
Respondent determined that petitioners are liable for 1992
for the addition to tax under section 6651(a)(1) for failing to
file timely their 1992 return. Except for the amount of compen-
sation that petitioner received from JMS during 1992, petitioners
do not contest respondent's determination under section
6651(a)(1).
On the record before us, we find that petitioners are liable
for 1992 under section 6651(a)(1) for the addition to the tax
attributable to $9,100 of income from JMS that they did not
report in their 1992 return.
Section 6662(a)
Respondent determined that petitioners are liable for 1992
for the accuracy-related penalty under section 6662(a) because
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Last modified: May 25, 2011