Memorandum Findings of Fact and Opinion
PARKER, Judge:
Respondent determined a deficiency in petitioner's Federal self-employment tax for the year 1977 in the amount of $1,240.53. The only issue involves the constitutionality of the self-employment tax or, more specifically, whether or not respondent's denial of an exemption from the self-employment tax under sections 1401 and 1402
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