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Respondent determined a deficiency in petitioners' Federal
income tax for the year 1993 in the amount of $1,700.
The issue for decision is whether petitioners are liable for
self-employment tax on income received by Marvin F. Foster
(hereinafter referred to as petitioner) for the year 1993.
Some of the facts have been stipulated and are so
found. The stipulations of fact and attached exhibits are
incorporated herein by this reference. Petitioners resided in
Cherokee, Texas, when they filed their petition.
Petitioner was born on June 20, 1928. He was graduated from
the University of Texas with a B.A. in 1952 and an LL.B. in 1954.
From 1954 until 1976, he practiced law in the State and Federal
courts in Texas. From 1976 until 1981, petitioner, his wife, and
his son had a corporate business in San Antonio.
In about 1982, petitioners purchased a ranch in San Saba
County, Texas, and retired to the ranch in 1985. They raised
cattle, goats, and horses on the ranch, and petitioner practiced
what little law he had to in order to supplement his income.
From 1987 until 1991, petitioner was employed by the Texas
State Comptrollers Office as the attorney for the Enforcement
Division. In 1991, petitioner left his State employment and
returned to his private law practice and semi-retirement. In
March 1991, he applied for Social Security benefits.
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