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curiam T.C. Memo. 1969-159. We find petitioner's testimony
in this case to be wholly incredible. Based upon all of
the foregoing, we sustain respondent's determination that
petitioner realized at least $3,158,000 of unreported
income in 1983 from the sale of marijuana.
Self-Employment Tax
Respondent determined that petitioner is liable for
the self-employment tax prescribed by section 1401.
Section 1401(a) imposes a tax "on the self-employment
income of every individual". Self-employment income is
defined generally as "net earnings from self-employment",
which in turn is defined as "the gross income derived by
an individual from any trade or business carried on by such
individual, less the deductions allowed by this subtitle
which are attributable to such trade or business". Sec.
1402(a) and (b).
Section 1402(c) provides that the term "trade or
business" as used in this regard "shall have the same
meaning as when used in section 162 (relating to trade or
business expenses)". This includes an illegal trade or
business such as selling illegal drugs. See Petzoldt
v. Commissioner, 92 T.C. at 698; Johnson v. Commissioner,
T.C. Memo. 1994-350; see also Reed v. Commissioner, T.C.
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