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deductions for that year. Petitioner also failed to pay
estimated tax as required by the Internal Revenue Code.
Gross income includes all income derived from any sources
whatsoever, unless specifically excluded by another provision of
the Internal Revenue Code. Sec. 61(a); Commissioner v. Glenshaw
Glass Co., 348 U.S. 426, 430 (1955). It is clear that commission
income is taxable income. There is nothing in this record which
would indicate that petitioner did not receive commission income
during 1993 in the amounts claimed by respondent. The evidence
in the record that petitioner did receive such income is
sufficient to carry respondent's burden of proof in that regard.
Section 1401 imposes a tax on self-employment income.
Section 1402 defines net earnings from self-employment as gross
income derived from a trade or business. Petitioner did not
appear at trial or present any information or evidence that the
commissions received were not self-employment income. The
evidence adduced by respondent establishes that these commissions
were income from self-employment. Accordingly, we conclude that
petitioner is liable for the self-employment tax.
Section 6651(a)(1) imposes an addition to tax for failure to
file a timely return. The addition to tax will not apply if the
failure to file was not due to willful neglect, and there was
reasonable cause for the failure to file. United States v.
Boyle, 469 U.S. 241, 245 (1985). Petitioner received substantial
amounts of income during the taxable year 1993, and he did not
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