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employment tax and has failed to meet his burden of proof.
Therefore, we sustain respondent’s determination that petitioner
is liable for self-employment tax.
In reaching our holdings, we have considered all arguments
made, and, to the extent not mentioned above, we conclude that
they are moot, irrelevant, or without merit.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: November 10, 2007