- 14 -
In sum, petitioner has presented no reliable evidence to
establish that the fair market value of the Mark IV helmet at
issue was $76,700 at the time he donated it to the museum.7
Based on our examination of the entire record before us, we find
that petitioner has failed to satisfy his burden of proving that
the Mark IV helmet at issue had a fair market value of $76,700 at
that time. We further find on that record that the fair market
value of that helmet at the time he donated it to the museum was
$500.
Self-Employment Tax
Petitioner presented no evidence and makes no argument
regarding his liability for self-employment tax for 1991. We
note that petitioner's failure to pay self-employment tax for
1988 was an issue raised in this Court in Droz v. Commissioner,
an Oral Opinion of this Court dated Oct. 14, 1992. In that case,
petitioner challenged the constitutionality of section 1402(g)(1)
to the extent that it provided that a self-employed individual
who raised religious objections to the social security system but
who did not belong to a religious organization was not entitled
to an exemption from self-employment tax. In our Oral Opinion,
we rejected petitioner's constitutional challenge. Petitioner
7 Petitioner provided no credible explanation as to why that
helmet, which he purchased for $100 in June 1977, would have so
substantially appreciated in value to $76,700 approximately 14
years later. See Tripp v. Commissioner, 337 F.2d 432, 434-435
(7th Cir. 1964), affg. T.C. Memo. 1963-244.
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