Jeffrey S. Kaiser and Gail F. Kaiser - Page 13

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          petitioner's off-duty activities severely undermines petitioners'           
          position in this case.  Consequently, and for the reasons                   
          expressed in March v. Commissioner, supra, we hold that the                 
          earnings here in dispute were not received by petitioner as an              
          employee of the Department, but constituted earnings from self-             
          employment within the meaning of section 1402, subject to the tax           
          imposed by section 1401.                                                    
               To reflect the foregoing,                                              
                                                  Decision will be                    
                                             entered for respondent.                  





























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