Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
For their taxable years ended December 31, 1974, 1975 and 1976, respondent has determined deficiencies in petitioners' Federal income tax in the respective amounts of $693.66, $755.23, and $757.74. The issues presented for our decision are as follows:
(1) Whether petitioner Albert B. Hess is subject to self-employment tax pursuant to sections 1401 and 1402
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