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RADCLIFF v. COMMISSIONER

Docket No. 36023-86.

59 T.C.M. 61 (1990)

T.C. Memo. 1990-122

Charles L. Radcliff and Ermagean Radcliff v. Commissioner.

United States Tax Court.

Filed March 8, 1990.

Attorney(s) appearing for the Case

S. Craig Wakefield, 920 W. Emmett St., Kissimmee, Fla., for the petitioners. Avery Cousins III, for the respondent.

Memorandum Findings of Fact and Opinion

SWIFT, Judge:

Respondent determined a deficiency in petitioners' joint Federal income taxes for 1981 in the amount of $70,999.15, and an addition to tax under section 6653(b)1 in the amount of $35,499.58. The issues for decision are: (1) The amount of petitioners' taxable income for 1981; (2) whether income petitioner Charles L. Radcliff earned in 1981 is subject to self-employment taxes...

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