Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency of $336.96 in self-employment tax against petitioners for the taxable year 1979. The sole issue presented is whether it is fair to impose self-employment tax upon petitioners who earned such a low income.
Findings of Fact
All of the facts were stipulated. The stipulation of facts and attached exhibits are incorporated by this reference.
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