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that petitioner carried on his real estate activity for a period
of no less than 2 years. In addition, illegal business
activities have been found to be subject to the self-employment
tax. See, e.g., Basada v. Commissioner, T.C. Memo. 1998-144.
Petitioner bears the burden of showing that the income
derived from his real estate activity was not from self-
employment. Rule 142(a). Petitioner has not refuted the ample
record in this case reflecting that petitioner was self-employed.
Therefore, it is held that petitioner is subject to self-
employment taxes to be computed under Rule 155.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011