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burden of proving otherwise. Rule 142(a); Welch v. Helvering,
290 U.S. 111, 115 (1933). Section 61(a) includes in gross income
all income from whatever source derived including, but not
limited to, compensation for services. Sec. 61(a)(1).
American
Petitioner concedes that he received $300 for services
performed as American's employee. We hold that such amount is
includable in his gross income. Sec. 61(a)(1).
D&B
Petitioner concedes that he received nonemployee
compensation from D&B for services performed during 1993. He
disputes, however, respondent's determination that he received a
total of $2,099 from D&B. Respondent submitted photocopies of 10
of D&B's canceled checks made out to petitioner in the total
amount of $2,099. At trial, petitioner verified his signature on
photocopies of the back of each of the 10 checks. Based on this
evidence and petitioner's concession, we find that he received
nonemployee compensation from D&B in the amount of $2,099 during
1993 and hold that such amount is includable in his gross income
and is subject to self-employment taxes.
Bryant
Petitioner concedes that he received $2,025 for services
performed for Bryant. He does not concede, however, that he is
subject to self-employment taxes for such amount.
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