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In addition petitioner also worked for Motel 6 during 1991 and
received wage income in the amount of $5,963.
In the notice of deficiency respondent determined that
petitioner received wage income from Motel 6 in the above amount
and that petitioner received additional income based upon BLS
statistics in the amount of $11,606. Respondent further
determined that this additional income was subject to the self-
employment tax. We find that petitioner received wage income
from Motel 6 as determined in the notice of deficiency, that he
had income from Everex, Heritage, and Peppermill in the amounts
listed above, and that none of the income is subject to the self-
employment tax. In doing so, we reject the portion of
respondent's adjustment that is based upon BLS statistics.
1992
In 1992 petitioner was employed by Motel 6. He earned
$9,328, and respondent appropriately made such an adjustment in
the notice of deficiency. We accept petitioner's assertion that
he had no other income for the year 1992. Consequently, we
reject the portion of respondent's adjustment based upon BLS
statistics. Because petitioner was married as of the close of
1992, his Federal income tax liability for 1992 must be computed
accordingly.
Section 6651(a)(1) Addition to Tax
For each year in issue respondent determined that petitioner
is liable for the addition to tax under section 6651(a)(1) for
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