Don H. Wisden - Page 6

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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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