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worked as a physician's assistant for multiple employers and
received wages in the amounts of $50,882 and $67,131,
respectively. During 1991, 1992, and 1993, petitioner earned
nonemployee compensation from her self-employment as a
physician's assistant in the amounts of $3,500, $2,115, and
$71,291, respectively. In addition, petitioner received
unemployment compensation in the amount of $920 in 1992 and
interest income in the amount of $12 in 1991. In total,
petitioner received income during the years in issue as follows:
Year Amount
1991 $54,382
1992 69,246
1993 71,291
Petitioner did not file income tax returns for any of the
years in issue, nor was any tax withheld or paid on income that
she earned in those years.
Discussion
Petitioner argues that her income was from her employment
and falls under the provisions of subtitle C. This Court lacks
jurisdiction in matters arising under subtitle C. Sec. 7442;
Judd v. Commissioner, 74 T.C. 651, 652-653 (1980). Accordingly,
petitioner contends that we lack subject matter jurisdiction over
this case. Subtitle C imposes employment tax on wages of
individuals required to be withheld by employers which is in
addition to income tax imposed by subtitle A. Subtitle A imposes
an income tax on an individual's taxable income, determined from
gross income. Section 61(a) defines gross income as "income from
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