- 2 - Respondent determined deficiencies in petitioner's Federal income taxes for the taxable years 1992 and 1993 in the amounts of $2,134 and $2,518, respectively. After a concession,2 the sole issue is whether petitioner is liable for self-employment tax for the years in issue. Petitioner resided in Enon Valley, Pennsylvania, at the time the petition was filed. FINDINGS OF FACT The facts are not disputed and may be summarized as follows. Petitioner is a carpenter. During the taxable years 1992 and 1993, petitioner's sole source of income was income earned from self-employment in the amounts of $6,724 and $7,708, respectively. Petitioner did not pay any self-employment tax for the years in issue. In the notice of deficiency, respondent determined that petitioner is liable for self-employment tax for the taxable years 1992 and 1993 in the amounts of $950 and $1,089, respectively. Petitioner contends that the self- employment tax does not, or at least should not, apply to individuals at his modest income level. OPINION Section 1401 imposes Social Security and medicare taxes (self-employment tax) on income derived by an individual from a 2 Respondent concedes that petitioner is entitled to earned income credits pursuant to sec. 32 for the taxable years 1992 and 1993 in the amounts of $1,184 and $1,429, respectively.Page: Previous 1 2 3 Next
Last modified: May 25, 2011