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HUVAL v. COMMISSIONER

Docket No. 6941-82.

50 T.C.M. 1452 (1985)

T.C. Memo. 1985-568

Louisa Huval v. Commissioner.

United States Tax Court.

Filed November 20, 1985.

Attorney(s) appearing for the Case

Clarence P. Brazill, Jr., 5010 University Ave., Lublock, Tex., for the petitioner. James R. Turton and W. Jere Blackshear, for the respondent.

Memorandum Opinion

NIMS, Judge:*

Respondent determined a deficiency of $1,390 in petitioner's 1978 Federal income tax. After concessions, the issue for decision is whether Louisa Huval petitioner) was carrying on a trade or business such that her one-half community property interest in income from the sale of oil and gas is subject to self-employment tax pursuant to sections 1401 and 1402, I. R. C. 1954.1

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