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are attributable to such trade or business". Section 1.1402(a)-
2(b), Income Tax Regs., provides that "The trade or business must
be carried on by the individual, either personally, or through
agents or employees." See also S. Rept. 1669, 81st Cong., 2d
Sess. (1950), 1950-2 C.B. 302, 354. These provisions are to be
broadly construed to favor treatment of income as earnings from
self-employment. Hornaday v. Commissioner, 81 T.C. 830, 834
(1983). Respondent's determination that petitioner is liable for
self-employment tax is presumed to be correct, and petitioner
bears the burden of proving it is erroneous. Rule 142(a); Kasey
v. Commissioner, 33 T.C. 656, 660 (1960); Ahmad v. Commissioner,
T.C. Memo. 1997-85.
At trial, petitioner testified that he was "self-supporting"
and that he was not an employee of Masterguard. Petitioner
offered no other evidence as to how he supported himself during
1988, the year in issue. Therefore, we hold that petitioner has
not met his burden of proving that respondent's determination is
incorrect and hold petitioner liable for self-employment tax on
the unreported income as determined by respondent for 1988.
Section 6651(a) imposes an addition to tax for a taxpayer's
failure to file a required return on or before the specified
filing date, including extensions. The addition to tax is
inapplicable, however, if the taxpayer shows that the failure to
file the return was due to reasonable cause and not willful
neglect. Sec. 6651(a)(1).
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