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On his 1993 Schedule C, petitioner returned self-employment
income of $16,906. Petitioners also reported on their joint
Federal return Social Security benefits of $16,677. Petitioner
did not report any self-employment tax on the 1993 return.
Upon audit of their 1993 Federal income tax return,
respondent determined that petitioners are liable for self-
employment tax of $1,700.
Petitioner contends that for 1993, he should not have been
"required to pay a self-employment tax or old age, survivor, and
disability tax on self-employed income, is because (sic) I am now
drawing the full entitlement under Social Security that I will
ever draw."
We have previously considered and rejected petitioner's
argument. In Steiner v. Commissioner, 55 T.C. 1018 (1971), affd.
per curiam 72-1 USTC par. 9327, 29 AFTR2d 72-848 (D.C. Cir.
1972), we held that a self-employed individual who was a "fully
insured individual" within the meaning of Title 42 U.S.C. sec.
414(a)(2) (Social Security Act), because he had over 40 quarters
of coverage, and accordingly, had his rights to old-age and
survivor benefit payments fully vested, nevertheless was required
to continue to pay self-employment tax on his earnings. We said
in Steiner v. Commissioner, supra at 1020: "Petitioner's argument
is without merit. It finds no support in any provision of the
Internal Revenue Code, in any regulation of the Commissioner, in
any congressional report, or in any provision of the
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