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petitioner’s earnings from AAA amounted to $6,350 (computed by
subtracting gifts from family members plus the income earned by
Mrs. Quintero reported on their 1997 return from the total
deposits made to the checking account).
We consider petitioners’ various claims as to the amount of
income petitioner earned during 1997 against the amount reflected
on AAA’s records.1 The accuracy of AAA’s monthly payroll
records, although not beyond question, is supported by the
pattern of deposits into petitioner’s checking account. All
things considered, we find AAA’s records more reliable than
petitioners’ various and inconsistent claims as to the amount of
compensation that petitioner received from AAA during 1997.
Accordingly, respondent’s determination that petitioner earned
and received compensation totaling $23,552 from AAA during 1997
is sustained.
2. Self-employment tax
In addition to the income tax imposed by section 1, section
1401(a) imposes a tax upon a taxpayer's self-employment income.
Disregarding irrelevant exceptions, "self-employment income" is
defined as "net earnings from self-employment", which, in turn,
is defined as "the gross income derived by an individual from any
1 We note that at trial respondent did not exclusively rely
upon the Form 1099. AAA’s payroll records as well as the
testimony of the person responsible for maintaining those records
were also admitted into evidence. See sec. 6201(d).
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