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182.1 Respondent determined a deficiency in petitioners' 1991
Federal income tax in the amount of $1,121.
The issue for decision is whether certain income earned by
Jeffrey S. Kaiser constitutes earnings from self-employment
within the meaning of section 1402, subject to tax imposed by
section 1401.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioners filed a joint Federal income tax return for
the year 1991 (the 1991 return). Jeffrey S. Kaiser resided in
Dallas, Texas, and Gail F. Kaiser resided in Mesquite, Texas, at
the time that the petition was filed in this case. References to
petitioner are to Jeffrey S. Kaiser.
Petitioner has been employed as a police officer on a full-
time basis by the Dallas Police Department (the Department) since
1981. During the year in issue he held the rank of sergeant.
In order for an individual to obtain employment as a police
officer in Texas, he or she must satisfy various requirements
established by Texas law, which include being issued a warrant of
appointment from a governmental entity authorized to do so.
As a Dallas police officer, petitioner was subject to the
Department's rules and regulations published in general orders
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year at issue. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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