Carol Anderson - Page 8

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          of $2,199 from her promotion activities.  Respondent determined             
          that such amount is subject to self-employment tax.                         
               Section 1401(a) imposes a tax on self-employment income for            
          old-age, survivors, and disability insurance.  An additional tax            
          for hospital insurance is imposed on self-employment income                 
          pursuant to section 1401(b).  Self-employment income is defined             
          as the net earnings from self-employment derived by an individual           
          during any taxable year.  Sec. 1402(b).  The phrase "net earnings           
          from self-employment" is in turn defined as gross income derived            
          by an individual from any trade or business carried on by such              
          individual, less any attributable deductions.  Sec. 1402(a).                
               Based on the record, we find that petitioner has not                   
          established that her promotion activities do not constitute a               
          trade or business carried on by her in her individual capacity.             
          She presented no reliable evidence that she is properly treated             
          as an employee of another person with respect to her promotion              
          activities.  Accordingly, we hold that petitioner is liable for             
          self-employment tax as determined by respondent.                            
               The sixth issue for decision is whether petitioner is                  
          entitled to a medical expense deduction for 1993.  Petitioner               
          claimed a medical expense deduction in the amount of $10,082 on             
          her 1993 return.  In the statutory notice of deficiency,                    
          respondent disallowed the claimed deduction.                                
               Section 213(a) allows as a deduction the expenses paid                 
          during the taxable year, not compensated for by insurance or                




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