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the amount of $833.1 After a concession by respondent,2 the
issues for decision are as follows:
(1) Whether petitioner is liable for income tax on his
wages.3 We hold that he is.
(2) Whether petitioner is liable for the addition to tax for
failure to file a timely return. We hold that he is.
FINDINGS OF FACT
Some of the facts have been stipulated, and they are so
found. Petitioner resided in Indianapolis, Indiana, at the time
that his petition was filed with the Court.
1 All section references are to the Internal Revenue Code
in effect for the taxable year in issue, and all Rule references
are to the Tax Court Rules of Practice and Procedure. All
amounts are rounded to the nearest dollar.
2 Respondent concedes that during the year in issue
petitioner was not an independent contractor as determined in the
notice of deficiency and, consequently, that he is not liable for
self-employment tax on his income. As a result, petitioner is
not entitled to the mechanical adjustment for one half of the
self-employment tax allowed in the notice of deficiency. See
sec. 164(f).
3 Although petitioner has not expressly raised the issue,
he appears to contend that he is not liable for any taxes,
including Social Security and Medicare taxes, for 1995. We note
that this Court has no jurisdiction to decide whether petitioner
is liable for Social Security and Medicare taxes in respect of
his income. Congress has only given this Court authority to
decide disputes with respect to certain types of taxes, the most
notable example of which is the income tax. See sec. 7442; Judd
v. Commissioner, 74 T.C. 651, 653 (1980); Griffin v.
Commissioner, T.C. Memo. 1995-246; see also Wilt v. Commissioner,
60 T.C. 977, 978 (1973).
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