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The issues remaining for decision are:2
(1) Does petitioner have nonemployee compensation income
for 1992 and 1993 in the amounts of $121,823 and $108,914,
respectively? We hold that he does.
(2) Is petitioner liable for self-employment tax for each
of the years 1992 and 1993? We hold that he is.
(3) Is petitioner liable for the addition to tax under
section 6651(a) for each of the years 1992 and 1993? We hold
that he is to the extent stated herein.
(4) Is petitioner liable for the addition to tax under
section 6654(a) for each of the years 1992 and 1993? We hold
that he is to the extent stated herein.
Petitioner resided in Trenton, Texas, at the time the
petition was filed.
Petitioner bears the burden of proving that respondent's
determinations in the notice are erroneous. Rule 142(a); Welch
v. Helvering, 290 U.S. 111, 115 (1933).
In answering respondent's requests for admissions, peti-
tioner admitted that he received $121,823 and $108,914 from First
National Life and Health as nonemployee compensation during 1992
and 1993, respectively. However, he claims that such compensa-
tion is not income and that he is not subject to tax on such
compensation.
2 At trial, respondent conceded the determination in the notice
of deficiency (notice) that petitioner had capital gain in the
amount of $24,000 for 1993.
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