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concedes that he did not keep track of the cash he received from
Lighthouse and was unable to provide even an estimate of the
amounts received from, or the number of deliveries made on behalf
of, the company. Even accepting petitioner's contention that he
kept all of his records in his truck and that they were destroyed
when the truck burned in an accident in 1992, we do not believe
this affects the result in this case, in light of petitioner's
concession that he did not keep any record of the cash he
received from Lighthouse in 1989 and 1990. Accordingly, we
conclude that petitioner has failed to meet his burden of proving
that the amounts of unreported Schedule C gross receipts
determined by respondent for the years in issue are erroneous.
Therefore, we sustain respondent's determinations, which were
based upon income-producing activities that petitioner concedes
occurred and which bear a rational relationship to amounts that
petitioner concedes he earned from similar income-producing
activities in the immediately subsequent year.
Respondent also determined that petitioner is liable for
self-employment taxes pursuant to section 1401 of $1,926 for 1989
and $4,849 for 1990. Section 1401 imposes a tax on self-
employment income, which consists of the gross income derived
from any trade or business carried on by the taxpayer less
allowable deductions attributable to such trade or business.
Sec. 1402(a). Respondent's determination that petitioner is
liable for self-employment tax on his Schedule C gross receipts
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