Memorandum Findings of Fact and Opinion
STERRETT, Judge:
By letter dated March 7, 1979 respondent determined a deficiency in income taxes due from petitioner Richard David Hayes and his wife Beverly G. Hayes for their taxable year ended December 31, 1977 in the amount of $1,155.39. The only issue for our decision is whether Mr. Hayes was denied equal protection of the laws when his application for exemption from self-employment tax was rejected.
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