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such taxes are calculated and based on the earnings of
the person responsible for such income. [Reproduced
literally.]
With respect to the first contention quoted above, we
conclude that that contention is not pertinent to resolving the
issue in this case and does not require any change to the Special
Trial Judge’s recommended findings of fact and conclusions of
law.
With respect to the second contention quoted above, we note
initially that the record does not establish that petitioner
“never acquired assets jointly with her husband.” Assuming
arguendo that the record had established the second contention
quoted above, we conclude that that contention would not require
any change to the Special Trial Judge’s recommended findings of
fact and conclusions of law.
With respect to the third contention quoted above, we note
initially that, as discussed supra note 2, income earned by a
self-employed individual is subject to self-employment tax, and
not FICA tax. Moreover, an individual having net earnings from
self-employment of $400 or more for a taxable year is required to
make a return with respect to the self-employment tax imposed on
such earnings. Sec. 6017. A husband and wife may make a single
return jointly, sec. 6013(a), and are jointly and severally
liable for the entire liability shown due in such a return, sec.
6013(d)(3), including the liability with respect to net earnings
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