Charles A. Dennis and Alison M. Dennis - Page 7

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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               
               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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