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subject to self-employment tax. See secs. 1402(a)(2),
1402(c)(2), 3121(d)(1). Petitioner, however, failed to establish
that the remaining $225,071.27 (i.e., $477,071.27 - $252,000) was
not net earnings from a trade or business carried on by him in
his individual capacity. Indeed, petitioner acknowledged that he
received an undetermined amount of finder's fees from M&L
investors and brokers. Accordingly, we hold that he is liable
for self-employment tax on $225,071.27.
IV. Additions to Tax and Accuracy-Related Penalties
Respondent determined that petitioner was liable for
additions to tax for failing to file his Federal income tax
returns in a timely manner as well as an addition to tax and
accuracy-related penalties for negligence.
Section 6651(a) imposes an addition to tax for failure to
file Federal income tax returns in a timely manner. Petitioner
introduced no evidence relating to this issue. Accordingly, we
hold that he is liable for the section 6651(a) additions to tax.
Section 6653(a), which is applicable to petitioner's 1988
tax year, imposes an addition to tax if any part of an
underpayment is attributable to negligence or disregard of rules
or regulations. Section 6662, which is applicable to
petitioner's 1989 and 1990 tax years, imposes an accuracy-related
penalty on the portion of an underpayment that is attributable to
negligence or disregard of rules or regulations. Negligence is
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