Sita G. and Mangalore Krishna - Page 4

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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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