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presumed to be correct, and petitioner bears the burden of
proving it wrong. See Rule 142(a); Welch v. Helvering, 290 U.S.
111 (1933).
Petitioner disputes all the determinations made by
respondent in the notice of deficiency. Petitioner’s argument,
as stated in his amended petition to this Court, is based upon
his “disputation of the claim on the fact or theory that the
federal income system or scheme is a system or scheme of
‘voluntary compliance.’” This argument is clearly without merit:
Petitioner was legally required to file a Federal income tax
return for taxable year 1996, see sec. 6012(a)(1)(A), and was
legally required to report thereon all income he received during
the year, as required by respondent, see sec. 6011(a).
Respondent determined that the amounts of $1,605 and $8,886
received by petitioner in 1996 from Nebraska Keno Operators,
Inc., and National Petition Management, respectively, were
includable in his income. Petitioner did not produce evidence
refuting this determination. Thus, petitioner must include these
amounts in his income. See sec. 61(a).
Respondent also determined that these amounts were self-
employment income within the meaning of section 1402(b).
Petitioner again did not present evidence refuting this
determination. Thus, petitioner is liable for self-employment
tax for 1996 figured from self-employment income in the total
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Last modified: May 25, 2011