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such a finding, and we base our conclusion that all of the income
earned from these jobs was earned during 1991 on petitioner's
testimony, even though such testimony was admittedly imprecise.2
In addition, during 1991 petitioner worked for Motel 6 and
received $5,963 in wages from that employer. It is unknown to
what extent, if any, these periods of employment overlapped.
During 1992 petitioner worked for Motel 6. His wages ranged
from $4 to $4.25 per hour and his total compensation from that
employer amounted to $9,328 for the year. Petitioner was married
as of the close of 1992.
In the notice of deficiency respondent reconstructed
petitioner's gross income for each year in issue in accordance
with the above table. She also determined that the nonemployee
compensation and BLS income constitutes earnings from self-
employment subject to the tax imposed by section 1401. In
computing petitioner's taxable income for each year respondent
allowed deductions that are not in dispute, or that will be
2On cross-examination, in response to questions specifically
addressing the dates when petitioner began working for certain
employers, petitioner testified:
I may have been off a year or so because I didn't
keep records of the amounts of compensation that I
received. I also didn't -- obviously didn't keep
records of the dates and times that I worked for the
various entities. So, if I said I worked for somebody
in * * * [one year] and I actually worked for them in *
* * [a different year], it's not because I'm trying to
mislead anybody or anything. It's because my memory is
faulty on those years in question.
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