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sec. 1402(a). Respondent determined that petitioner is liable
for self-employment taxes under section 1401 as part of the
deficiencies at issue for 1990 and 1991. The evidence in this
case indicates that petitioner earned self-employment income from
both the California Barbecue and the Thru The Lens activities.
Petitioner has offered no evidence or argument to rebut that
evidence. He is liable for the self-employment tax for 1990 and
1991 determined by respondent and asserted in the amendment to
answer.
D. Additions to Tax Under Section 6651(a)(1)
Respondent determined additions to tax under section
6651(a)(1) for failure to file returns. Petitioner did not file
Federal income tax returns for the years in issue. He makes only
tax-protester arguments in response to the charge that he failed
to file such returns. Accordingly, the additions to tax under
section 6651(a)(1) determined by respondent and asserted in the
amendment to answer are sustained.
E. Additions to Tax Under Section 6654(a)
Respondent determined additions to tax under section 6654(a)
for underpayment of individual estimated tax. Petitioner failed
to pay estimated tax during the years in issue. Accordingly, the
additions to tax under section 6654 determined by respondent and
asserted in the amendment to answer are sustained.
In view of the foregoing,
Decision will be entered
for respondent.
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