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Commissioner, 85 T.C. 731, 742-743 (1985). Thus, petitioner may
not deduct any amount for business expenses in the years in
issue.
D. Whether Petitioner Is Liable for Self-Employment Tax
Petitioner does not deny that he is liable for self-
employment tax. However, he testified that King of Construction
paid wages to him. If that were true, he would not be liable for
self-employment tax.
Petitioner testified that money from Terminex went into an
account in the name of King of Construction. He paid business
expenses from the account and kept what was left. We conclude
that payments from Terminex are self-employment income to
petitioner, and not wages. We conclude that petitioner is liable
for self-employment tax in the years in issue.
E. Whether Petitioner Is Liable for the Additions to Tax for
Failure To File Returns for 1994, 1995, and 1996, for
Failure To Pay Tax for 1996, and Failure To Pay Estimated
Tax for 1994, 1995, and 1996
Petitioner contends in his petition that he is not liable
for the additions to tax for failure to file timely returns and
pay tax under section 6651(a)(1) or (2), or for failure to pay
estimated tax under section 6654. Petitioner concedes that he
did not file a tax return or pay any tax, including estimated
tax, for 1994, 1995, or 1996. He offered no evidence as to why
he failed to do so. We conclude that petitioner is liable for
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