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K-1 for 1993, as would have been required if it had been a
partnership. Sec. 6031(a) and (b). Petitioner did not report
any partnership income on his 1993 return. Petitioner offered no
documents and called no witnesses to corroborate his testimony
that Stan’s Pawn Shop was a partnership in 1993. We are not
convinced that Stan’s Pawn Shop was a partnership in 1993.
Petitioner contends that he is not liable for tax on $25,218
because the business kept that amount and made no cash
distribution to him. We disagree. Stan’s Pawn Shop had net
income of $25,218. For tax purposes, a sole proprietorship has
no separate legal identity from its proprietor. Jaske v.
Commissioner, 823 F.2d 174, 176 (7th Cir. 1987), affg. T.C. Memo.
1986-454. Petitioner is liable for income tax on the $25,218,
whether or not Stan’s Pawn Shop distributed that amount in cash
to him. Id.
We conclude that petitioner is liable for tax on $25,218 of
net income from Stan’s Pawn Shop in 1993.
D. Whether Petitioner Is Liable for Self-Employment Tax
Petitioner contends that he is not liable for self-
employment tax on income from Stan’s Pawn Shop because it was a
partnership. We disagree for reasons discussed at paragraph C,
above.
Petitioner contends that he is not liable for self-
employment tax because he was not an employee of Stan’s Pawn Shop
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