Memorandum Findings of Fact and Opinion
GOFFE, Judge:
The Commissioner determined a deficiency in petitioner's income tax in the amount of $400 for the taxable year 1973. The sole issue for decision is whether petitioner is exempt from self-employment tax by reason of his religious beliefs. At the trial respondent contended that petitioner was collaterally estopped from trying this issue before the Court because he presented the issue under our small tax...
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