-22-
Thus, there is no credible evidence that the deposits were from
nontaxable sources. Based on the entire record, we simply do not
believe that the money came from the sources petitioner claims.
We find, therefore, that petitioner has not met his burden of
proof with respect to the funds that he claims are family
transfers, cash repayments of loans he made earlier, or
reimbursements for checks he wrote on behalf of others.
Issue 3. Self-Employment Tax
Respondent determined that petitioner had income in the
amounts of $24,592, $74,634, and $86,464 for 1991, 1992, and
1993, respectively, and that he is liable for self-employment tax
of $3,351, $8,862, and $9,435 for those years.
Section 1401 imposes a tax on self-employment income. Self-
employment income consists of gross income from any trade or
business carried on by an individual less allowable deductions
attributable to the trade or business. Sec. 1402(a).
Respondent's determination that petitioner is liable for self-
22(...continued)
capital of Amman"; however, because his father was frequently in
need of cash, petitioner had to wire him transfers of what were
often relatively modest amounts. In addition, petitioner
testified that many people owe him money, and that he carries the
balance of the loans in his head, yet he can only approximate the
amounts he has been repaid. Finally, petitioner testified that
he did not believe he owed taxes in 1991, 1992, and 1993 because
the terms of his immigration prevented his steady employment.
Petitioner testified that he actually did work in 1991, his legal
status notwithstanding. Petitioner also testified he became a
resident alien during 1991. Thus, petitioner's immigration
status was not a legal obstacle to his employment during the
latter part of and forever after 1991.
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