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We hold that petitioner is not entitled to business expense
deductions in excess of the amounts allowed by respondent.
The third issue for decision is whether petitioner's net
earnings from self-employment are excludable from self-employment
income because he was a nonresident alien.
Section 1401(a) imposes a tax on self-employment income for
old-age, survivors, and disability insurance. An additional tax
for hospital insurance is imposed on self-employment income
pursuant to section 1401(b). Self-employment income is defined
as the net earnings from self-employment derived by an
individual, other than a nonresident alien individual, during any
taxable year. Sec. 1402(b). The phrase "net earnings from self-
employment" is in turn defined as gross income derived by an
individual from any trade or business carried on by such
individual, less any attributable deductions. Sec. 1402(a).
Petitioner argues that he is not liable for the section
1401(a) and (b) taxes on self-employment income because he was a
nonresident alien during 1992 and 1993.
A nonresident alien never has self-employment income. Sec.
1.1402(b)-1(d), Income Tax Regs. While a nonresident alien who
derives income from a trade or business carried on within the
United States may be subject to the applicable income tax
provisions on such income, such nonresident alien will not be
subject to the taxes on self-employment income, since any
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