OPINION
HALL, Judge:
This case is before the Court on respondent's motion for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
At the time they filed their petition, petitioners resided in Oelwein, Iowa. Respondent determined deficiencies in petitioners' 1975 and 1976 income tax of $1,019.10 and $909.84, respectively. The sole issue in this case is whether petitioners are subject to the self-employment...
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