OPINION
STERRETT, Chief Judge:
By notice of deficiency dated February 2, 1983, respondent determined a deficiency in petitioner's Federal income tax return for the taxable year ended December 31, 1979, in the amount of $1,390.28. After concessions, the sole issue before us is whether the income earned by petitioner is subject to self-employment tax under section 1401.
The facts have been fully stipulated pursuant...
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