SANDRIDGE v. COMMISSIONER

Docket No. 11947-78.

40 T.C.M. 280 (1980)

T.C. Memo. 1980-152

John R. Sandridge v. Commissioner.

United States Tax Court.

Filed May 1, 1980.


Attorney(s) appearing for the Case

John R. Sandridge, pro se. Francis J. Elward, for the respondent.


Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined deficiencies in self-employment taxes in the amounts of $1,114 for 1975 and $922 for 1976 and has now filed a motion for summary judgment, maintaining that there is no genuine issue as to any material fact.

The petition alleges that petitioner is not subject to the self-employment tax as follows:

Briefly, under present laws covering death estate taxes and the cost of dieing [sic...

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