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that all Social Security taxes had been paid relating to his
insurance business income. The notice of deficiency addressed
only the issue of self-employment tax on petitioner's C.P.A.
business income. We conclude that petitioner is liable for self-
employment tax on his C.P.A. business income based upon the
amount shown on the return and the amount of disallowed Schedule
C deductions.
IV. Dependency Exemptions
On brief, petitioner argued for the first time that he is
entitled to dependency exemptions for his two children.
Respondent argues that (1) petitioner is not entitled to
dependency exemptions because during 1992 he did not provide more
than one-half of his children's support, and (2) in the
alternative, the dependency exemption issue is not before the
Court.
Section 151(c) allows a deduction for a "dependent" as
defined in section 152. Sons or daughters of the taxpayer, over
half of whose support during the calendar year is provided for by
the taxpayer, are "dependents". Sec. 152(a). Section 152(e)(1),
however, further provides that if a child receives over half of
his support during the calendar year from parents who live apart
at all times during the last 6 months of the calendar year, and
if the child is in the custody of one or both of his parents for
more than one-half of the calendar year, then the child is
treated as receiving over half of his support during the year
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