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because of that increase in net profit, the self-employment tax
due from each petitioner should be increased from that reported
in the 1994 Schedules SE. Respondent also determined in the
notice that petitioners are liable for 1994 for the accuracy-
related penalty under section 6662(a) because of negligence or
disregard of rules or regulations under section 6662(b)(1).
OPINION
Petitioners bear the burden of proving that the determina-
tions in the notice are erroneous and that their position regard-
ing the new issues that they raised in the petition and at trial
should be sustained. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933).
Self-Employment Tax
Petitioners reported in their 1994 Schedule C the rental
payments that they received and the expenses that they claimed
from the activity in which they engaged during 1994 involving the
ten parcels in question and which they described in that schedule
as a property management business. Petitioners now contend that
they should have reported those payments and those expenses for
1994 in Schedule E, Supplemental Income and Loss (Schedule E),
and not in their 1994 Schedule C, because they were not engaged
during 1994 in a trade or business involving the ten parcels as
real estate dealers. According to petitioners, they had no net
profit from a business as real estate dealers, and therefore had
no net earnings from self-employment, for 1994. They maintain
that, therefore, they are not liable for self-employment tax for
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