K & M La Botica Pharmacy, Incorporated, Et Al. - Page 7

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          defined as the net income derived by an individual from any trade           
          or business carried on by such individual.  Sec. 1402(a) and (b).           
          Exceptions from inclusion in net earnings from self-employment              
          are construed narrowly.  Johnson v. Commissioner, 60 T.C. 829,              
          833 (1973).                                                                 
               As explained in our prior opinion, because he completely               
          controlled all aspects of the nominee corporations and because he           
          treated the nominee corporations as his alter ego in connection             
          with his trade or business of providing medical services and                
          products and other related activities, Ahmed earned the income              
          that was collapsed and charged to him personally.  Because Ahmed            
          earned the collapsed income in his trade or business, the income            
          constitutes net earnings from self-employment and thus self-                
          employment income.                                                          
               As explained, at trial Ahmed stipulated that the collapsed             
          income from the nominee corporations would be treated as earned             
          by Ahmed individually.  The stipulation does not indicate that              
          the collapsed trade or business income should be treated                    
          differently from other trade or business income earned by Ahmed.            
               Respondent, in his notice of deficiency, determined that               
          self-employment taxes should be imposed on income collapsed from            
          the nominee corporations.  On brief, Ahmed did not specifically             
          argue that respondent improperly imposed self-employment taxes on           
          the collapsed income, and we therefore conclude that Ahmed                  






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