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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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