Memorandum Findings of Fact and Opinion
SHIELDS, Judge:
In these consolidated cases respondent determined deficiencies in petitioner's Federal income taxes as follows:
Docket No. Year Deficiency 10323-81 1978 $612.97 23070-81 1979 932.21
The only issue for our decision is whether petitioner is liable for self-employment tax, pursuant to section 1401, with respect to compensation he received in the...
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