Robert Schelble and Susan Schelble - Page 13

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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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