MEMORANDUM OPINION
PAJAK, Special Trial Judge:
Respondent determined a deficiency in petitioners' Federal income tax in the amount of $7,606 for the taxable year 1995. Unless otherwise indicated, section references are to the Internal Revenue Code in effect for the year in issue.
After a concession by petitioners, the only issue which this Court must decide is whether petitioners are liable for self-employment tax under section 1401 on a distribution...
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