Christopher Richardson - Page 9

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               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 conclude           
          that the income attributable to petitioner from Eniva Corp. in              
          2000 and 2001 is earnings from self-employment under section                
          1402, subject to the tax imposed by section 1401.                           
          D.   Filing Status and Exemptions                                           
               Petitioner did not file returns for the years in issue.                
          Respondent determined that petitioner’s filing status was single            
          and allowed petitioner one exemption.  Petitioner offered no                
          evidence on these points.  We deem petitioner to have conceded              
          these issues.  See Funk v. Commissioner, 123 T.C. 213, 217-218              
          (2004); Swain v. Commissioner, 118 T.C. 358, 363-365 (2002).                
          E.   Whether Petitioner Is Liable for Additions to Tax                      
               Section 7491(c) places on the Commissioner the burden of               
          producing evidence that it is appropriate to impose additions to            
          tax.  To meet the burden of production under section 7491(c), the           
          Commissioner must produce evidence showing that it is appropriate           
          to impose the particular addition to tax, but need not produce              
          evidence relating to defenses such as reasonable cause or                   







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