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Petition because Petitioners had no notice that
these adjustments would be proposed, neither side
offered any evidence about these issues, and it
is too late now to raise them for the first time.
Respondent would have had to timely move for
permission to seek an increased deficiency and
properly plead these matters for them to be
issues.
We note that neither party takes issue with the
adjustment made in the notice of deficiency to the self-
employment tax reported by Mr. Lemons for 1988.
Accordingly, that adjustment is hereby sustained. We
also note that no adjustment was made in the notice of
deficiency to the self-employment tax reported by
Mrs. Lemons for 1988.
In the case of respondent's adjustment to the self-
employment tax reported by Mr. Lemons for 1987, petitioners
bear the burden of proving that respondent's adjustment is
incorrect. Rule 142(a). They did not take issue with this
adjustment in Mr. Lemons' petition or at trial.
Accordingly, petitioners have failed to meet their burden
of proof, and we hereby sustain respondent with respect to
this adjustment.
As mentioned, no adjustment was made in the notice
of the deficiency to the self-employment tax reported by
Mrs. Lemons for 1987, and respondent has not sought to
amend the Government's pleadings to raise such an adjust-
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