Ronald E. Reed - Page 14

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          years in question with respect to the totality of the                       
          underpayment for that year.                                                 



          V.  Self-Employment Tax                                                     
               The last issue is whether petitioner is liable for self-               
          employment taxes.  A self-employment tax is imposed on income               
          earned from self-employment.  Sec. 1401.  Respondent determined             
          that petitioner was liable for self-employment taxes on account             
          of income from drug trafficking in the amounts of $2,097, $1,324,           
          and $5,387, for the years 1985, 1986, and 1987, respectively.               
          Petitioner has assigned error to respondent’s determination of              
          self-employment taxes but has not averred any facts in support of           
          that assignment.  We assume that petitioner relies on our finding           
          that he received no (or a reduced amount of) income from drug               
          trafficking to support his assignment of error.  Petitioner bears           
          the burden of proof.  Rule 142(a).  Petitioner has failed to                
          carry his burden of proof.  Therefore, we sustain the                       
          determination of self-employment taxes, modified only as                    
          necessary to take into account one adjustment agreed to by the              
          parties.                                                                    
               To reflect the foregoing,                                              








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