James E. Anderson and Cheryl J. Latos - Page 45

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          is not properly before the Court in this case; petitioners’                 
          argument is not relevant to determine petitioner’s self-                    
          employment status at issue in this case because petitioners did             
          not file this case under section 6330 and respondent has not yet            
          sought to collect petitioners’ 1997 self-employment tax                     
          liability.  We observe in conclusion, however, that nothing we              
          say or do in the case at hand has any negative impact on the                
          ultimate collectibility of the deficiency resulting from our                
          determination.                                                              
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        for respondent.                               

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