-4-
7. Whether petitioners are liable for self-employment tax
under section 1401 for the years in issue. We hold that they
are.
Section references are to the Internal Revenue Code in
effect for the years in issue. Rule references are to the Tax
Court Rules of Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
A. Petitioners
Petitioners lived in Tacoma, Washington, when they filed the
petition in this case. Petitioners are married and filed joint
Federal income tax returns for each of the years in issue.
James E. Peacock (petitioner-husband) served in the U.S.
Army for a total of 20 years over a 26-year period. He had tours
of duty in Korea, Germany, and Vietnam. His duties included
managing clubs for enlisted personnel, noncommissioned officers,
and officers. Petitioner-husband retired from the Army in 1976.
Petitioner-husband met Chung H. (Judy) Peacock (petitioner-
wife) in 1958 while serving a tour of duty in Korea. Petitioners
were married in Korea in 1961. Petitioner-wife immigrated to the
United States in 1963.
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