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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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