Dwight D. Spann - Page 2

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               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.                     




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