9
D. Self-Employment Tax
Respondent determined that petitioner is liable for
self-employment taxes under section 1401 for 1992 and 1993.
Section 1401 imposes a tax on a taxpayer's self-employment
income. Self-employment income includes the net earnings from
self-employment derived by an individual during the taxable year.
Sec. 1402(b). Net earnings from self-employment income means
gross income, less certain deductions, derived by an individual
from any trade or business carried on by the individual. Sec.
1402(a). Petitioner bears the burden of proving that he is not
liable for the taxes imposed by section 1401. Rule 142(a).
Petitioner offered no evidence or argument on this issue
other than tax protester contentions. Petitioner is liable for
the self-employment tax for 1992 and 1993.
E. Failure To File Tax Returns
Respondent determined that petitioner is liable for the
addition to tax for failure to file a return for 1992 and 1993.
Sec. 6651(a).
Section 6651(a)(1) imposes an addition to tax of up to 25
percent of the tax required to be shown on the return for failure
to timely file Federal income tax returns unless the taxpayer
shows that the failure was due to reasonable cause and not
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