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The term “self-employment income” denotes “net earnings from
self-employment”. Sec. 1402(b). “Net earnings from self-
employment”, in turn, means “the gross income derived by an
individual from any trade or business carried on by such
individual, less the deductions allowed by this subtitle which
are attributable to such trade or business”. Sec. 1402(a).
Because, as explained above, the burden has not shifted to
respondent under section 7491(a) with respect to the deficiency
determinations, petitioner bears the burden of proving error in
the statutory notices as regards the self-employment tax issue.
Rule 142(a). Respondent determined that petitioner is liable for
self-employment taxes in the amounts of $4,080 and $4,490 by
virtue of the nonemployee compensation received from GCE in 2000
and 2001, respectively. Again, petitioner has offered no
evidence or argument pertaining to the self-employment tax.
Hence, to the extent that we have sustained respondent’s
determinations of unreported nonemployee compensation, we
likewise sustain the imposition of the corresponding self-
employment tax thereon.
IV. Additions to Tax
Section 7491(c) places on the Commissioner the burden of
production regarding additions to tax. The burden with respect
to “reasonable cause, substantial authority, or similar
provisions” then shifts to the taxpayer. Higbee v. Commissioner,
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