Docket No. 22283-94.

72 T.C.M. 1357 (1996)

T.C. Memo. 1996-526

Jeffrey S. Kaiser and Gail F. Kaiser v. Commissioner.

United States Tax Court.

Filed November 27, 1996.

Attorney(s) appearing for the Case

Lawrence R. Jones, Jr., Dallas, Tex., for the petitioners. Audrey M. Morris, for the respondent.


CARLUZZO, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 Respondent determined a deficiency in petitioners' 1991 Federal income tax in the amount of $1,121.

The issue for decision is whether certain income earned by Jeffrey S. Kaiser constitutes earnings from self-employment within the meaning of section 1402...

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