- 49 - 1992 Gross receipts Notice of Deficiency $91,972 Star Bank miscellaneous (886) Total 91,086 Purchases Notice of Deficiency 58,971 Additional 10,313 Dishonored checks (18,130) Total 51,154 Omitted Income Gross receipts 91,086 Purchases (51,154) Rent (5,000) Total 34,932 Issue 2. Whether Petitioners Are Liable for Self-Employment Tax on the Net Income From the Sports Memorabilia Activity Section 1401 imposes a tax on a taxpayer's self-employment income. Self-employment income includes the net earnings from self-employment derived by an individual during the taxable year. See sec. 1402(b). Net earnings from self-employment means the gross income derived by an individual from any trade or business carried on by the individual, less allowable deductions attributable to the trade or business, plus certain items not relevant here. See sec. 1402(a). With certain exceptions not here applicable, the term "trade or business" for purposes of the self-employment tax generally has the same meaning as used for purposes of section 162. Sec. 1402(c). Thus, to be engaged in a trade or business within the meaning of section 1402(a), an individual must be involved in an activity with continuity and regularity, and the primary purpose for engaging in the activity must be for income and profit. See Commissioner v. Groetzinger,Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 Next
Last modified: May 25, 2011