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received by petitioner are subject to self-employment tax on the
grounds that they were derived by petitioner from a trade or
business carried on by petitioner within the meaning of section
1402.
For the foregoing reasons, we hold that the "extended
earnings" received by petitioner, in the amounts stipulated, are
subject to self-employment tax under sections 1401 and 1402.
Decision will be entered
for respondent.
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Last modified: May 25, 2011