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trade or business (self-employment income) in excess of $400 to
pay for old-age, survivors and disability insurance, and hospital
insurance. Secs. 1401 and 1402(b) and (c); Culp v. Commissioner,
T.C. Memo. 1984-78. Since petitioner's self-employment income
for each of the years in issue exceeds $400, petitioner is liable
for self-employment tax in the amounts determined in the notice
of deficiency. As to the fairness of such a taxing regime,
petitioner's avenue of redress lies with Congress, for we must
apply the law as written. Metzger Trust v. Commissioner, 76 T.C.
42, 59-60 (1981), affd. 693 F.2d 459 (5th Cir. 1982).
To reflect respondent's concession,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011