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PRICE v. COMMISSIONER

Docket No. 23040-91.

65 T.C.M. 2968 (1993)

T.C. Memo. 1993-265

William A. Price v. Commissioner.

United States Tax Court.

Filed June 16, 1993.

Attorney(s) appearing for the Case

Gino P. Cecchi, 2134 Van Ness St., San Francisco, Calif., for the petitioner. Lin Murphy, for the respondent.

Memorandum Opinion

WOLFE, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency of $5,859 in petitioner's Federal income tax for 1988.

The sole issue for decision is whether the net profits received by petitioner from his convalescent hospital are net earnings from self-employment and subject to self-employment tax.<...

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