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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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