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Petitioner was no more specific about the income he earned in
1990 than he was with respect to 1989.
In the notice of deficiency, in addition to an adjustment
based upon BLS statistics, respondent determined that petitioner
earned $6,792 in nonemployee compensation and had wage income in
the amount of $5,729. The sources of the nonemployee
compensation and wage income were not specifically identified,
but petitioner did not specifically deny the receipt of such
income. We assume that the sources of income were Tucson
Newspapers, Inc., and Delivery Services, Inc. Having found
petitioner to be a credible witness, we accept his contention
that he had no other sources of income for the year 1990. We
further find that the nonemployee compensation is subject to the
self-employment tax imposed by section 1401. We reject the
portion of respondent's adjustment that is based upon BLS
statistics.
1991
Although the exact date is unknown, petitioner moved to St.
George, Utah, in late 1990. After he moved to St. George,
petitioner worked for Everex, Heritage, and Peppermill. Based
upon his testimony we find that he earned the following income in
connection with these jobs:
Employer Amount Computation
Everex $2,280 12 weeks x 40 hrs. per week x $4.75 per hr.
Heritage 2,160 12 weeks x 40 hrs. per week x 4.50 per hr.
Peppermill 2,640 12 weeks x 40 hrs. per week x 5.50 per hr.
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