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proprietorship and had net profits of $86,960 and $90,719 in 1997
and 1998, respectively. Therefore, petitioners could afford to
operate the horse training and breeding activity as a hobby, and
we conclude that they sought to reduce or eliminate their tax
liability by using the losses from the horse activity to offset
income from other sources.
H. Conclusion
After reviewing the entire record, we conclude that
petitioners did not engage in the horse breeding activity with an
actual and honest objective of making a profit within the meaning
of section 183.
II. Self-Employment Tax
Section 1401(a) imposes a tax upon the self-employment
income of every individual. Self-employment income consists of
gross income an individual derives from carrying on any trade or
business. Sec. 1402(a) and (b); Spiegelman v. Commissioner, 102
T.C. 394, 396 (1994). Petitioner operated his chiropractic
practice as a sole proprietorship and had net profits of $86,960
and $90,719 in 1997 and 1998, respectively. Petitioners deny
that they are liable for self-employment tax. On brief regarding
this issue, petitioners advanced arguments characteristic of tax
protester rhetoric that has been universally rejected by this and
other courts. See Wilcox v. Commissioner, 848 F.2d 1007 (9th
Cir. 1988), affg. T.C. Memo. 1987-225; Carter v. Commissioner,
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