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Self-Employment Tax
Section 1401 provides that a tax shall be imposed on the
self-employment income of every individual. Petitioners have the
burden of proving that they are not liable for self-employment
taxes. Rule 142(a). Petitioners failed to offer any evidence or
make any arguments that they are not liable for self-employment
taxes. Consequently, we hold that petitioners are liable for
self-employment taxes.
Social Security Benefits
Section 86 requires that, if a taxpayer's modified adjusted
gross income plus one-half of his or her Social Security benefits
exceeds a certain base amount, a portion of the taxpayer's Social
Security benefits shall be included in taxable income.
Petitioners failed to offer any evidence or make any arguments
with respect to respondent's determination with respect to this
4(...continued)
mass of materials ostensibly to substantiate the medical and
dental expenses claimed on their Form 1040 as filed, as well as
the additional amounts claimed at trial for hearing aids. The
materials are not readily susceptible of interpretation or
analysis. One receipt, for example, in the amount of $5,900,
does not identify the purpose of the receipt; nor is there proof
of payment such as a canceled check. Other than to contend that
they are entitled to additional deductions for hearing aids,
petitioners did not testify regarding these alleged expenses or
call any witnesses to support their claim to the deductions. On
the basis of this record, the Court is unable to ascertain
whether the medical expenses claimed on the return in fact
exclude the expenses for hearing aids, or the extent to which any
of these items may represent allowable unreimbursed medical
expenses under sec. 213.
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Last modified: May 25, 2011