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determination that he received unreported income with respect to
Pieces of Eight during those years.
Section 1401 Self-Employment Tax
Respondent determined that petitioner is liable for self-
employment tax on the following amounts of unreported income from
Pieces of Eight for the years in issue:
Year Amount
1987 $92,446
1988 37,891
1989 58,577
Section 1401 imposes a tax on the self-employment income of every
individual. The term “self-employment income” generally is
defined as an individual’s net earnings from self-employment
during any taxable year that do not exceed the contribution and
benefit base provided by section 230 of the Social Security Act,
42 U.S.C. sec. 430 (1988), for that year. Sec. 1402(b). “Net
earnings from self-employment” generally are defined as the gross
income from any trade or business carried on by the individual,
less allowable deductions attributable to the trade or business.
Sec. 1402(a). Petitioner bears the burden of establishing error
in respondent’s determination that he is liable for self-
employment tax on the net earnings of Pieces of Eight. Rule
142(a).
We have rejected above petitioner’s claim that Ms. Murphy
was sole owner of the business, and we have sustained
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