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II. Self-Employment Tax
Respondent determined that petitioner, pursuant to section
1401, is liable for self-employment tax of $5,859, $5,978,
$4,359, $4,558, and $4,666 for 1988, 1989, 1990, 1991, and 1992,
respectively. Section 1401 imposes a tax on self-employment
income. Self-employment income consists of gross income from any
trade or business carried on by an individual less allowable
deductions attributable to the trade or business. Sec. 1402(a).
Respondent's determination that petitioner is liable for self-
employment tax is presumed to be correct, and petitioner bears
the burden of proving that it is erroneous. Rule 142(a); Kasey
v. Commissioner, 33 T.C. 656, 660 (1960).
Petitioner introduced no evidence relating to the self-
employment tax issue. Therefore, petitioner has failed to carry
his burden of proof and is liable for self-employment tax for
1988 and 1989. He is not liable, however, for self-employment
tax with respect to 1990, 1991, and 1992, because we have
concluded that there are no deficiencies for those years.
III. Additions to Tax for Failure To File Timely Returns
Respondent determined that petitioner, pursuant to section
6651(a)(1), was liable for additions to tax for failure to file
timely Federal income tax returns. Section 6651(a)(1) imposes an
addition to tax for failure to file a timely return, unless it is
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