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income adjustments relating to the medical and healthcare
payments are sustained.
II. Self-Employment Tax
Section 1401 imposes a tax on the self-employment income of
individuals. Self-employment income means the net earnings from
self-employment derived by an individual. Sec. 1402(b).
Respondent determined the medical and healthcare payments
received by petitioner constituted self-employment income and
consequently petitioner was liable for self-employment tax.
Petitioner bears the burden of proving respondent’s determination
incorrect. See Rule 142(a); Welch v. Helvering, supra at 115.
Petitioner argues he is not liable for self-employment tax
because “Respondent has failed to establish self-employment
income”. As described above, respondent established petitioner
received income from medical and healthcare payments received for
services rendered by petitioner. Petitioner presented no
testimony or evidence regarding his liability for self-employment
tax and has failed to meet his burden of proof. Therefore, we
conclude that petitioner is liable for self-employment tax.
III. Addition to Tax Under Section 6651(a)(1)
Section 6651(a)(1) imposes an addition to tax for failure to
file a return on the date prescribed, unless the taxpayer can
establish that such failure is due to reasonable cause and not
willful neglect. Respondent determined petitioner is liable for
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