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derived by an individual from any trade or business carried on by
such individual, less the deductions * * * which are attributable
to such trade or business”. Sec. 1402(a). Petitioners have made
no contention and offered no evidence as to whether they are
liable for self-employment taxes during the years in issue. The
record, however, demonstrates that petitioners’ gross receipts
during 2000 and 2001 were attributable to their business, Kingdom
Kreations. Consequently, we conclude that respondent correctly
determined that petitioners had self-employment income of
$111,109 for the 2000 tax year and $146,518 for the 2001 tax
year, representing petitioners’ gross receipts less business
expense deductions for each respective tax year. Accordingly, we
hold that petitioners are liable for the corresponding self-
employment taxes as determined by respondent with respect to the
years in issue.
We now turn to the issues of whether petitioners are liable
for the addition to tax for failure to timely file pursuant to
section 6651(a)(1) with respect to petitioners’ 2000 tax year and
whether petitioners are liable for section 6662 accuracy-related
penalties for the years in issue. Section 7491(c) provides that
respondent bears the burden of production with respect to the
liability of any individual for any addition to tax or penalty.
Consequently, respondent must produce sufficient evidence to
demonstrate that the addition to tax for failure to file timely
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Last modified: May 25, 2011