Memorandum Opinion
WRIGHT, Judge:
By notice of deficiency dated February 16, 1982, respondent determined a deficiency of $991 in petitioners' 1979 Federal income tax. The issue for decision is whether petitioner David E. Priebe, an American citizen, is liable for United States self-employment taxes on income earned while employed in Canada.
The facts have been stipulated and are so found. The stipulation of facts and exhibits thereto are incorporated...
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