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1402(a). Respondent determined that petitioner failed to pay
self-employment taxes of $3,533 and $3,002 for 1992 and 1993,
respectively. Respondent based his determination on petitioner’s
lack of adequate records establishing that she was not subject to
self-employment taxes with respect to the cash transactions.
Petitioner argues that she is not liable for self-employment
taxes because she did not carry on any trade or business.
Petitioner has failed to prove that the cash transactions
involved proceeds from a nontaxable source. She has failed to
prove that such proceeds did not arise in connection with a trade
or business. We sustain respondent’s determinations of
deficiencies to the extent allocable to the taxes on self-
employment income.
II. Section 6662(a) Accuracy-Related Penalties
Section 6662 provides for an accuracy-related penalty in the
amount of 20 percent of the portion of any underpayment
attributable to, among other things, negligence or intentional
disregard of rules or regulations (hereafter, simply,
negligence). Respondent determined section 6662 penalties
against petitioner for her negligence with respect to the total
underpayment for 1992 and 1993. Petitioner contests the section
6662 penalties only to the extent that they relate to the cash
transactions. Negligence has been defined as the failure to
exercise the due care of a reasonable and ordinarily prudent
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