- 12 -
512, 514-516 (1971). Although petitioner provided Jacqueline
with an occasional place of abode, some food, and perhaps some
clothing, Jacqueline had other means of support during 1992. She
earned wages from her part-time job, lived at school, sometimes
purchased food while at home, and reimbursed her parents for
expenses such as car insurance and clothes. On this record,
petitioner has not established that he provided more than one-
half of Jacqueline's total support during 1992. Respondent,
therefore, is sustained on this issue.4
Issue 3. Self-Employment Tax
Respondent determined that petitioner's unreported income in
1991 and 1992 was subject to self-employment taxes under section
1401.
Section 1401 imposes a tax on a taxpayer's self-employment
income. Self-employment income includes the net earnings from
self-employment derived by an individual during the taxable year.
Sec. 1402(b). Net earnings from self-employment means gross
income derived by an individual from any trade or business
4 On their original 1991 return, petitioners claimed
their children Jacqueline and Johnathan as dependents. On their
amended 1991 return, petitioners added another child, James, as a
dependent. Respondent allowed the dependents as reflected on the
original 1991 return. Petitioners did not address this at trial;
thus, respondent is sustained on this determination.
On their original 1992 return, petitioners claimed
Jacqueline as a dependent. On their amended 1992 return,
petitioners again added James as a dependent. The exemption for
Jacqueline is denied, as set forth above; however, respondent
concedes the 1992 exemption for James.
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