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STEVENSON v. COMMISSIONER

Docket No. 437-88.

57 T.C.M. 1032 (1989)

T.C. Memo. 1989-357

Carl and Floy M. Stevenson v. Commissioner.

United States Tax Court.

Filed July 24, 1989.

Attorney(s) appearing for the Case

Carl and Floy M. Stevenson, pro se. Emile L. Herbert III, for the respondent.

Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in the amount of $1,979.72 in petitioners' tax on self-employment income for 1984. The issue to be decided is whether petitioners' income from the rental of portable advertising signs is subject to taxation under section 1401(a)1 as self-employment income.

All of the facts are stipulated.

At the time the petition was filed, Carl and Floy...

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