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for the years at issue. That is not the situation here. The
cases of Scar v. Commissioner, 814 F.2d 1363 (9th Cir. 1987), and
Couzens v. Commissioner, 11 B.T.A. 1040 (1928), cited by
petitioner, are inapposite.
Accordingly, we hold that petitioner received taxable income
in the amounts determined by respondent for the years 1990
through 1993.
2. Self-employment Taxes
Section 1401 imposes a tax on the "the self-employment
income" of every individual. In general, self-employment income
consists of "the net earnings derived by an individual (other
than a nonresident alien) from a trade or business carried on by
him as sole proprietor", less allowable deductions and certain
exclusions. Sec. 1402(a); sec. 1.1401-1(c), Income Tax Regs.
Petitioner presented no evidence contesting respondent's
determination that he is subject to self-employment tax under
section 1401. Therefore, we hold that petitioner is liable for
self-employment taxes in the amounts determined by respondent for
the years 1990 through 1993.
3. Section 6651(a)(1) Additions to Tax
For each year in issue respondent determined that petitioner
is liable for the addition to tax under section 6651(a)(1) for
his failure to file a Federal income tax return. Section
6651(a)(1) provides for an addition to tax in the amount of 5
percent of the amount of the tax if the failure to file is for
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