Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in the joint Federal income tax of Elizabeth Stevenson and Cyril Stevenson, Jr. (petitioner), in the amount of $467 for calendar year 1976. The issue for decision is whether petitioner is liable for self-employment tax imposed by section 1401, I.R.C. 1954,
Findings of Fact
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