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concluding that petitioner was not a statutory employee and was
engaged in a self-employment activity, the net income of which is
subject to self-employment tax as determined in the notice of
deficiency.
The second issue relates to adjustments in the notice of
deficiency as to the income and expenses reported by petitioners
on their income tax return for 2000 relating to the activity with
Corben reported on Schedule C.4
On Schedule C, petitioners reported gross receipts of
$61,100. In the notice of deficiency, respondent increased that
amount by $1,000. Petitioner did not address this adjustment at
trial; consequently, that adjustment is deemed conceded. As to
the expenses, the amounts deducted on Schedule C and the amounts
disallowed are as follows:
Claimed on Disallowed by
Return Respondent
Other expenses $ 7,599 $ 7,599
Car and truck expenses 14,046 14,046
Meals and entertainment 3,617 3,617
Repairs and maintenance 1,845 1,845
Travel 4,295 4,295
Legal and professional 876 876
As to the other expenses of $7,599 shown above, respondent
at trial conceded that petitioner was entitled to a deduction of
4In the notice of deficiency, respondent determined capital
gain income of $816. At trial, petitioner conceded this
adjustment.
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