Steve J. Work - Page 17

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               We conclude in accordance with section 1401 that petitioner            
          is liable for additional self-employment tax in 1999 and 2000 on            
          his additional self-employment income from the disallowed                   
          Schedule C deductions and cost of goods sold.                               
          IV. Conclusion                                                              
               To reflect respondent’s concessions at trial and on brief,             
          Rule 155 computations will be necessary.                                    
               To reflect the foregoing,                                              


                                                  Decisions will be entered           
                                             under Rule 155.                          



























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