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BARRERT v. COMMISSIONER

Docket No. 970-71.

58 T.C. 284 (1972)

HERBERT R. BARRETT AND JOYCE S. BARRETT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 11, 1972.

Attorney(s) appearing for the Case

Jerold A. Fink, for the petitioners.

Donald K. James, for the respondent.

OPINION

BRUCE, Judge:

Respondent determined a deficiency in self-employment tax of the petitioners for the calendar year 1969 in the amount of $538.20. The only issue is whether $12,000 received by the petitioner, Herbert Barrett, under a contract entered into between the Philip Carey Manufacturing Co. and petitioner on January 5, 1962, is self-employment income subject to tax under section 1401 of the Internal Revenue Code of 1954.

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