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Section 1401(a) imposes a tax on self-employment income for
old-age, survivors, and disability insurance. An additional tax
for hospital insurance is imposed on self-employment income
pursuant to section 1401(b). Self-employment income is defined
as the net earnings from self-employment derived by an individual
during any taxable year. Sec. 1402(b). The phrase "net earnings
from self-employment" is in turn defined as the gross income
derived by an individual from any trade or business carried on by
such individual, less any attributable deductions. Sec. 1402(a).
Petitioner presented no evidence or testimony which supports
a finding contrary to respondent's determination, and we
accordingly sustain such determination.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011