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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.
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