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JOHNSON v. COMMISSIONER

Docket No. 111-71.

60 T.C. 829 (1973)

DAVID E. JOHNSON AND MATTIE JOHNSON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 5, 1973.

Attorney(s) appearing for the Case

Samuel L. Payne, for the petitioners.

Robert J. Shilliday, Jr., for the respondent.

OPINION

FAY, Judge:

Respondent determined deficiencies in petitioner David E. Johnson's self-employment tax for the taxable years 1967 and 1968 in the amounts of $250.56 and $271.11, respectively. The sole issue for determination is whether income received from the rental of petitioner David E. Johnson's boat sheds constitutes rental income from real estate under section 1402(a)(1) of the Internal Revenue Code of 19541

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