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petitioner asserts that his deductions were reasonable; he must
provide adequate proof. See Wilkinson v. Commissioner, 71 T.C.
633, 639 (1979); Roberts v. Commissioner, 62 T.C. 834, 837 (1974)
(a tax return does not establish the correctness of the facts
stated in it).
We conclude that petitioner may not deduct more business
expenses than respondent allowed for 1999 and 2000.
B. Whether Petitioner Is Liable for Self-Employment Tax for
1999 and 2000
As discussed at paragraph A above, respondent disallowed
Schedule C expenses for 1999 and 2000. Respondent determined
that petitioner is liable for additional self-employment tax
under section 1401 of $5,339 for 1999 and $4,313 for 2000 and
that he may deduct under section 164(f) self-employment tax of
$2,671 for 1999 and $2,157 for 2000.
Section 1401 imposes a tax on an individual’s self-
employment income. The self-employment tax is imposed on net
earnings of $400 or more derived by an individual from a trade or
business carried on by him. Sec. 1402(a) and (b).
Petitioner did not prove that respondent’s determination of
his liability for self-employment tax was incorrect. We sustain
respondent’s determination.
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