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petitioner’s bank accounts were nontaxable. Furthermore, we find
that the $9,363 constitutes unreported gross receipts derived
from petitioner’s Schedule C businesses. Accordingly, we hold
that petitioner failed to report $9,363 of gross receipts from
his Schedule C businesses. Respondent is sustained on this
issue.
2. Self-Employment Tax
Respondent determined that petitioner is liable for self-
employment tax on the $9,363 of 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).
Above, we found that petitioner failed to report $9,363 of
gross receipts on his Schedules C. The unreported income
increases petitioner’s net earnings subject to self-employment
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