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determinations are erroneous. See Rule 142(a); Welch v.
Helvering, 290 U.S. 111, 115 (1933).4
Petitioner’s argument focuses on the use of the word
“contributions” in SECA’s title and relies upon what petitioner
claims is its plain meaning. Petitioner’s argument is misplaced.
Webster’s Collegiate Dictionary defines “contribution”, among
other things, as “a payment (as a levy or tax) imposed by
military, civil, or ecclesiastical authorities [usually] for a
special or extraordinary purpose”. Webster’s Collegiate
Dictionary 252 (10th ed. 1997). The use of the term
“contributions” in SECA’s title is consistent with the definition
cited above. Self-employment tax is a tax imposed by the United
States Government for a special purpose; i.e., to fund Social
Security and hospital insurance benefits. The taxation regime
established by SECA has been upheld as constitutional. See Cain
v. United States, 211 F.2d 375 (5th Cir. 1954); Egan v.
Commissioner, T.C. Memo. 1980-560, affd. without published
opinion (9th Cir. 1982).
Section 1401 imposes a tax on income earned from self-
employment in order to fund the payment of Social Security and
4Although respondent claimed increased additions to tax
under sec. 6651(a)(1) in his answer, as to which he bears the
burden of proof, see Rule 142(a), the issue is moot since
respondent has conceded that petitioner’s liability for the sec.
6651(a)(1) addition to tax for 1996 and 1997 is lower than that
determined in the notice of deficiency.
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