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conclusions of law were filed and served upon the parties.
Petitioner filed objections (petitioner’s objections) to the
Special Trial Judge’s recommended findings of fact and conclu-
sions of law. Respondent did not.
In petitioner’s objections, petitioner advances many of the
same contentions and arguments that she advanced at trial and/or
in her posttrial briefs. We conclude that the Special Trial
Judge gave appropriate consideration to those contentions and
arguments in making his recommended findings of fact and conclu-
sions of law.
In petitioner’s objections, petitioner also advances the
following three contentions:
[1] There is a legal means by which the Petitioner’s
husband [William E. Butner] would not have to pay
F.I.C.A. [Federal Insurance Contributions Act] taxes.[2]
It was to his advantage to do so, however he was
prohibited from doing so by the confiscations and
exorbitant expenses arising out of the actions of the
Bankruptcy Trustee over a period of many years.
[2] * * * the Petitioner has never acquired assets
jointly with her husband.
[3] * * * There is a distinct difference in income
taxes and F.I.C.A. taxes. The only reason F.I.C.A.
taxes are reported on the income tax return is because
2Income earned by a self-employed individual, as William E.
Butner (Mr. Butner) was during the years at issue, is not subject
to tax under sec. 3101, i.e., tax under the Federal Insurance
Contributions Act (FICA tax). Rather, such income is subject to
tax under sec. 1401, i.e., tax under the Self-Employment Contri-
butions Act of 1954 (self-employment tax). Self-employment tax
is imposed by the Code in subtitle A relating to “Income Taxes”.
See sec. 1401.
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