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petitioner is liable for self-employment tax under section 1401
on income received for the performance of off-duty security
services.
FINDINGS OF FACT
Some of the facts in this case have been stipulated and are
so found. Petitioner resided in Fort Worth, Texas, at the time
he filed his petition.
Since 1992, petitioner has been employed as a police officer
by the Fort Worth Police Department (Department). In 1995,
petitioner was working full-time as a patrol officer in a patrol
car. As a Fort Worth police officer, petitioner is required to
abide by the rules set forth in the Department's General Orders
Manual (manual) at all times, regardless of whether he is on or
off duty. An officer who at any time violates any of the rules
in the manual is subject to discipline.
The manual also contains detailed provisions that an officer
must follow to obtain off-duty employment outside of the
Department. Under these provisions, the Department allows its
officers to work both law enforcement or security jobs (off-duty
employment) and non-security related jobs after they receive
approval from the Department and pay a one-time $100
administrative fee for a permit.
The approval or denial of a request for off-duty work is
dependent upon the officer's work requirements and the type of
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