- 10 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: November 10, 2007