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4. Summary of 1995 Income
In sum, we find that Michael Friscia had the following
amounts of income in 1995:
Account Income
591/864/898 $2,785
533 20,760
522 18,452
------
Total 41,997
We further find that Michael Friscia reported gross receipts of
$37,801 in 1995, as follows:
Interest $221
Rental income 22,000
Mik Mic proceeds1 15,580
------
Total 37,801
1Unlike for 1994, respondent contests the amount Michael
Friscia testified he reported on the Mik Mic returns in 1995.
Respondent provides no explanation for this inconsistency. We
find Michael Friscia's testimony as to the amounts reported on the
Mik Mic returns to be equally credible as to both 1994 and 1995.
Accordingly, we hold that Michael Friscia underreported his income
for 1995 by $4,196 ($41,997 - $37,801).
Issue 3. Self-Employment Tax for 1994 and 1995
In the notice of deficiency, respondent determined that the
Friscias and Michael Friscia are liable for self-employment taxes
for the amounts underreported in 1994 and 1995, respectively. The
Friscias fail to offer any evidence or analysis of this issue and
so fail to meet their burden of proof. Accordingly, we hold that
the amounts underreported represent income from self-employment
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