-8-
We sustain respondent’s determination as to both items of
unreported income. In so doing, we note without further comment
that we consider it proper for respondent to have determined this
unreported income from the information received from the third
parties. E.g., Parker v. Commissioner, 117 F.3d 785 (5th Cir.
1997); see also Hardy v. Commissioner, 181 F.3d 1002, 1005 (9th
Cir. 1999), affg. T.C. Memo. 1997-97.
C. Whether Petitioner Is Liable for Self-Employment Tax
Section 1401 imposes a tax on the self-employment income of
every individual for old age, survivors, disability insurance,
and hospital insurance. Sec. 1401(a) and (b); Schelble v.
Commissioner, 130 F.3d 1388, 1391 (10th Cir. 1997), affg. T.C.
Memo. 1996-269; sec. 1.1401-1(a), Income Tax Regs.
Self-employment income includes the net earnings from
self-employment derived by an individual during the taxable year.
Sec. 1402(b). For purposes of the self-employment tax, the term
"net earnings from self-employment" is the gross income derived
by an individual from any trade or business carried on by such
individual, reduced by, inter alia, the deductions attributable
to the trade or business. Sec. 1402(a); sec. 1.1402(a)-1, Income
Tax Regs. Petitioner has failed to disprove that his earnings
were “net earnings from self-employment” within the meaning of
section 1402(a). Accordingly, we sustain respondent’s
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