- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011