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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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