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respondent attributed to him in the notice of deficiency.
Initially, petitioner took the position that he was not a
"taxpayer" for the years in issue, and attempted at trial to
present support for that proposition; however, it appears that
petitioner has abandoned that position3 and essentially only
disputes respondent's determinations based upon the use of the
BLS statistics and her determinations that certain of his income
was subject to the self-employment tax.
As we view the case, we need only determine the amount and
characterization of the compensation that petitioner received
during each year. Our analysis, which follows on a year-by-year
basis, takes into account the presumption of correctness
applicable to respondent's determinations, and our impression
that petitioner was a credible witness at trial.
1989
During 1989, petitioner worked as a newspaper carrier for
Tucson Newspapers, Inc., and as a delivery person for Delivery
Services, Inc. Petitioner could not remember, and did not
estimate at trial, how much he earned from either of these jobs,
3In a chambers conference that took place following the
trial, the Court warned petitioner against presenting frivolous
arguments in his brief and called his attention to sec. 6673.
Petitioner complained in his brief that he was "intimidated" by
the Court during this conference. Due either to this perceived
intimidation, or the exercise of sound judgment, to his credit,
for the most part, he heeded the warning.
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