Adell Maxie, Jr. - Page 7




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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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