Dwayne Worth Champ - Page 3

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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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