- 8 - 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 orPage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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