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JOHNSON v. COMMISSIONER

Docket No. 7536-98.

87 T.C.M. 1057 (2004)

T.C. Memo. 2004-56

Gerald E. Johnson and Dorothy Johnson v. Commissioner.

United States Tax Court.

Filed March 9, 2004.

Attorney(s) appearing for the Case

Garry A. Pearson, Jon J. Jensen, and Alexander F. Reichert, for the petitioners.

Blaine C. Holiday, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

CHIECHI, Judge:

Respondent determined deficiencies of $3,764, $3,755, and $8,068 in petitioners' Federal income tax (tax) for 1993, 1994, and 1995, respectively.

We must decide1 whether certain amounts (reduced by the deductions attributable to such amounts) that petitioners received during the years at issue and that they characterized as rent are subject to self-employment tax...

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