Salaheddin Ahmad Ahmad - Page 23

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          employment tax is presumed to be correct, and petitioner bears              
          the burden of proving that it is erroneous.  Rule 142(a); Kasey             
          v. Commissioner, 33 T.C. 656, 660 (1960).                                   
               At trial, petitioner testified that during 1991 and 1992 he            
          worked at several restaurants.  Petitioner also testified,                  
          however, that he made very little money working at these                    
          restaurants, and the only Form W-2 petitioner received reported a           
          mere $585 of wage income, which gives credence to his claim.  We            
          are persuaded that petitioner did not earn the unreported income            
          determined by respondent, except for the amount reported on the             
          Form W-2, as an employee.                                                   
               Although petitioner has persuaded this Court that the source           
          of his unreported income was not wages, he has not met his burden           
          of proving that he did not receive such amounts from self-                  
          employment.  Thus, we find petitioner is liable for self-                   
          employment tax on the unreported income as determined by                    
          respondent for 1991, 1992, and 1993, except for the $585 of wage            
          income reported on the Form W-2 and the amounts that we have                
          found hereinbefore are not income.                                          
          Issue 4. Additions to Tax Under Section 6651(a)(1)                          
               Respondent determined petitioner is liable for additions to            
          tax for failure to file income tax returns for 1991, 1992, and              
          1993 under section 6651.                                                    
               Section 6651(a)(1) imposes an addition to tax for failure to           
          file a return on the date prescribed (determined with regard to             




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