-23- 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 toPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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