Memorandum Findings of Fact and Opinion
GUSSIS, Special Trial Judge:
This case was heard pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code and Rule 180 et seq.
Respondent determined a deficiency in petitioners' Federal income tax for 1984 in the amount of $4,271.40. The issue in this case is whether petitioner Atef A. Gamal-Eldin is liable for the self-employment tax imposed by section 1401...
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