- 6 -- 6 - 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-employmentPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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