- 10 -
Cir. 1971); Blackwell v. United States, 244 F.2d 423, 429 (8th
Cir. 1957).
Accordingly, we sustain respondent's determined deficiencies
for 1984, 1985, 1986, and 1987.
II. Self-Employment Tax
Respondent determined that petitioner, pursuant to section
1401, is liable for self-employment tax of $4,271.40, $4,672.80,
$5,166.00 and $4,577.66 for 1984, 1985, 1986, and 1987,
respectively.
Section 1401 imposes a tax on self-employment income. Self-
employment income consists of gross income from any trade or
business carried on by an individual less allowable deductions
attributable to the trade or business. Sec. 1402(a).
Respondent's determination that petitioner is liable for self-
employment tax is presumed to be correct, and petitioner bears
the burden of proving that it is erroneous. Rule 142(a); Kasey
v. Commissioner, 33 T.C. 656, 660 (1960).
Petitioner introduced no evidence relating to the self-
employment tax issue. Therefore, petitioner has failed to carry
his burden of proof and is liable for self-employment tax.
III. Additions to Tax for Fraud
Respondent determined that petitioner, pursuant to section
6653(b), is liable for additions to tax for fraud with respect to
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