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never made because his payments on the balance were current. The
debit balance was paid by later commissions earned (year not
shown). Because such later commissions covered the payment due
on the loans, petitioner was never required to make an out-of-
pocket payment on the debit balance.
Self-Employment Tax
Respondent determined that due to the increase in
petitioner's nonemployee compensation for the tax years 1988
through 1991, petitioners were liable for increased self-
employment tax under section 1401. Petitioner asserts that he
did not receive the income in question because the amounts
received constituted loan proceeds, and therefore there is no
self-employment tax due.
Additions to Tax
Petitioners neither requested nor received extensions of
time from the Internal Revenue Service to file their returns.
Petitioners did not timely file their returns for the years at
issue, and they do not deny that such returns were not timely
filed.
OPINION
Generally, petitioners have the burden of proving that the
determinations made by respondent in the notice of deficiency are
erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111 (1933).
Bank Fees
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