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resolved in accordance with the disputed issues. Petitioner's
Federal income tax liability was computed for each year using the
tax rates applicable to single individuals. As previously
indicated, for each year respondent also determined that the
additions to tax under sections 6651(a)(1) and 6654 are
applicable.
Discussion
The relevant law involved in this case could not be more
firmly established. Compensation for services constitutes income
within the meaning of section 61 regardless of whether the income
was earned as an employee or from self-employment, section
61(a)(1) and (2), and such income is subject to the tax imposed
by section 1. To the extent that any of petitioner's arguments
suggest the contrary, they are summarily rejected, and we see no
reason for further discussion on this point. See Charczuk v.
Commissioner, 771 F.2d 471 (10th Cir. 1985), affg. T.C. Memo.
1983-433.
In addition to other taxes, section 1401 imposes a tax upon
an individual's self-employment income. This tax is commonly
referred to as the self-employment tax. In general, section
1402(b) defines self-employment income as net earnings from self-
employment, which generally consist of the gross income derived
by an individual from any trade or business carried on by such
individual, less the allowable deductions which are attributable
to such trade or business. Sec. 1402(a). The self-employment
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