WILES, Judge:
Respondent determined deficiencies of $864.00 and $1,042.80 in petitioners' 1973 and 1974 Federal income taxes. The sole issue is whether petitioners' net rental income from their mobile home park is subject to self-employment tax under section 1402(a)(1).
FINDINGS OF FACT
Some facts are stipulated and are found accordingly.
Fabian and Florence Bobo, husband and wife, were legal residents...
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