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Hradesky v. Commissioner, 65 T.C. 87, 90 (1975) affd. per curiam
540 F.2d 821 (5th Cir. 1986); sec. 1.6001-1(a), Income Tax Regs.
At trial, petitioners introduced no evidence to substantiate
the amount or the purpose of the deductions that they claimed.
Consequently, we conclude that petitioners have not met their
burden of substantiating the amount and purpose of the deductions
claimed. Rule 142(a).
The next issue to be decided is whether petitioners are
liable for the self-employment tax pursuant to section 1401(b) in
the amount of $1,240. In the notice of deficiency, respondent
determined that petitioner's unreported income in the amount of
$46,311 constituted earnings from self-employment that were
subject to the self-employment tax in the amount of $1,240.
Petitioners bear the burden of proving that respondent's
determination is erroneous. Rule 142(a).
In their reply brief, petitioners argue that petitioner's
earnings are not subject to the self-employment tax. For
purposes of the self-employment tax, the term "net earnings from
self-employment" is the gross income derived by an individual
from any trade or business carried on by such individual, reduced
by, inter alia, the deductions attributable to such trade or
business. Sec. 1402(a). Relying on the sources of petitioner's
earnings set forth in the notice of deficiency, petitioners
contend that petitioner was not self-employed. We conclude,
however, that petitioners have not established that petitioner's
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