MEMORANDUM OPINION
NAMEROFF, Special Trial Judge:
Respondent determined a deficiency in petitioner's 1996 Federal income tax of $2,404. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
The issues for decision are: (1) Whether petitioner is liable for self-employment tax on amounts that he received from Strategic Telecom Systems, Inc. (Strategic); and (2) whether petitioner is entitled...
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