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evidence in this proceeding. The declaration of Ms. Wittman is
the affidavit of a third-party witness, not the affidavit of
respondent as the opposing party. Rule 143(b) has no application
in these circumstances.
E. Conclusion
In conclusion, the Court affirms the admission into evidence
at trial of the declaration of Ms. Wittman and the underlying
business records. The Court further is satisfied that the
totality of the evidence in the record is sufficient to satisfy
any pertinent burden of production placed on respondent with
respect to the unreported income at issue here. Moreover, the
documents in the record provide more than ample support for
respondent’s determinations in this regard, and petitioner has
offered no evidence or argument tending to show any error
whatsoever in the determinations. The Court holds that
petitioner received from GCE unreported income in the amounts
alleged in the notices of deficiency, i.e., wages of $31,027 and
$32,054 in 1999 and 2000, respectively, and nonemployee
compensation of $28,876 and $31,779 in 2000 and 2001,
respectively.
III. Self-Employment Tax
Section 1401 imposes an additional tax on the self-
employment income of every individual, both for old age,
survivors, and disability insurance and for hospital insurance.
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