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Section 1401 imposes a tax on an individual's net earnings
from self-employment. Self-employment income consists of gross
income from any trade or business carried on by an individual
less allowable deductions attributable to the trade or business.
Sec. 1402(a). Respondent's determination that petitioner is
liable for self-employment tax is presumed to be correct, and
petitioner bears the burden of proving that it is erroneous.
Rule 142(a); Kasey v. Commissioner, 33 T.C. 656, 660 (1960).
At trial, petitioner testified that he was not employed
during 1987 and 1988, nor does he recall having a job or an
employer from 1980 through 1994. We have found that petitioner
had unreported income in 1987 and 1988. Although petitioner has
persuaded this Court that he did not earn the unreported income
as an employee, he has not met his burden of proving that he did
not receive the unreported income from self-employment. Thus, we
find that petitioner is liable for self-employment tax on the
unreported income as determined by respondent for 1987 and 1988.
Issue 4. Additions to Tax Under Section 6654
Respondent determined that petitioner is liable for
additions to tax under section 6654(a) for his failure to make
estimated tax payments for 1987 and 1988.
Subject to exceptions provided by statute, the imposition of
the addition to tax is otherwise automatic if the amounts of the
withholdings and estimated tax payments do not equal statutorily
designated amounts. Niedringhaus v. Commissioner, 99 T.C. at
202; Grosshandler v. Commissioner, 75 T.C. 1, 20-21 (1980).
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