§6017 — Self-employment tax returns

on the separate self-employment income of each spouse.” § 6017; see also Treas.

1.6017-1(b)(1), Income Tax Regs 8 Each spouse's self-employmenttax liability is added to arrive at the couple's total self-employment tax liability. Sec. 6017; sec. 1.6017-1(b)(1), Income Tax Regs. The liability isjoint and several. Sec. 6013(d)(3). . 8 Sec. 1.6017-1(b)(1), Income Tax Regs., provides: In the case ofa husband and wif

On brief, petitioner invites us to ignore several other cases that support respondent’s determination because “none * * * take into account * * * the practical aspects of how to treat such an attribution of income * * * [to a married individual who files a separate] tax return.” Except as provided by section 6017,4 however, we fail to see how the filing status of the taxpayer makes any difference for purposes of section 1402(a)(5)(A).

, 446 (2001). As discussed above, petitioner was required to file a Federal income tax return for 2010. Because the parties have stipulated that petitioner did not file a tax return for 2010, respondent has met his burden ofproduction. 6In addition, sec. 6017 imposes a filing requirement on any individual who has net self-employment earnings of$400 or more. Petitioner's net self- employment earnings for 2010 exceed this amount. - 16 - [*16] Additionally, petitioner has not offered any documentar

In his petition, petitioner contends that his recycling ofnewspapers "was a 'hobby' type ofbusiness". However, petitioner and H and R Blocktreated the activity as a Schedule C business and used a disproportionate amount ofexpenses and the resulting net loss to offset other income. On the basis ofthe entire record, we have determined that

The notice ofdeficiency determined that petitioner was liable for self- employmenttax of$16,438 and allowed a self-employmenttax deduction of $8,219. We have found that petitioner is entitled to additional deductions that - 10 - [*10] respondent had disallowed in the notice ofdeficiency. Accordingly, this will change the amounts ofpetit

ese years, the IRS did not determine any deficiency in self-employment tax attributable to tribal-council compensation, The IRS's answers in these cases do not assert "This Court observed in Charlton v. Commissioner, 114 T.C. 333, 337 (2000) (citing sec. 6017): "Self-employment tax for a husband and wife filing a joint return is the sum of the taxes computed on the self-employment income of each spouse." "Sec. 6013 (d) (3) imposes joint-and-several liability on spouses who file joint returns. Se

Self-employment income consists of the net earnings from a trade or business carried on by an individual through a sole proprietorship. Sec. 1.1401-1(c), Income Tax Regs.; see also Parrish v. Commissioner, T.C. Memo. 1997-474, affd. 168 F.3d 1098 (3d Cir. 1999). Petitioner must take into account all of the income and deductions of his so

All of the gross income and deductions from a trade or business over which one spouse exercises substantially all of the management and control are attributable to that spouse. See sec. 1402(a)(5)(A). For these purposes, “management and control” means actual management and control even if management and control is imputed to the other sp

All of the gross income and deductions from a trade or business over which one spouse exercises substantially all of the management and control are attributable to that spouse. See sec. 1402(a)(5)(A). For these purposes, “management and control” means actual management and control even if management and control is imputed to the other sp

The taxpayer has the burden of proving that the addition is improper. Rule 142(a); United States v. Boyle, 469 U.S. 241, 245 (1985). Petitioner did not timely file Federal income tax returns for 1992, 1993, and 1994. For 1992, petitioner earned no more than $140 per year from refining gold. Accordingly, pursuant to section 6012(a), petit

Petitioner argues that his net self-employment income did not exceed $400 in 1984. We have determined, however, that petitioner is not entitled to various claimed deductions, causing petitioner’s net self-employment income to be greater than $400 in taxable year 1984. Accordingly, respondent is sustained on this issue. Issue 5. Negligen