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We find the testimony given by petitioner to be too vague
and based too much upon conjecture to establish that the $10,393
of bank deposits at issue were derived from credit card cash
advances, earnings from Merkle, or a combination of both.
Furthermore, we find no other evidence in the record which
establishes that the $10,393 of funds deposited into petitioner’s
checking bank account were nontaxable. In the absence of such
evidence, we must find for respondent on this issue.
2. Self-Employment Tax
Respondent determined that petitioner is liable for self-
employment tax on the unreported income. Section 1401 imposes a
tax on the self-employment income of individuals.
Self-employment income means the net earnings from self-
employment derived by an individual. Sec. 1402(b). In general,
net earnings from self-employment means the gross income derived
by an individual from any trade or business that he or she
carries on, reduced by allowable deductions attributable thereto.
Sec. 1402(a). Petitioner bears the burden of showing that
respondent's determination is erroneous. Rule 142(a); cf. Jones
v. Commissioner, T.C. Memo. 1994-230, affd. without published
opinion 68 F.3d 460 (4th Cir. 1995); O’Rourke v. Commissioner,
T.C. Memo. 1993-603, affd. without published opinion 60 F.3d 834
(9th Cir. 1995).
When asked at trial about his employment status, petitioner
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