Jaggard v. Commissioner
United States Tax Court
Held, petitioners are collaterally estopped from contending that sec. 1402(h), I.R.C. 1954, violates the establishment clause of the First Amendment. Held, further, petitioners are not similarly situated to members of Amish sects entitled to exempt status under sec. 1402(h). Held, further: Petitioners do not assert any facts which, if true, would establish that they are entitled to exempt status under sec. 1402(h). Respondent's motion for summary judgment granted.
1Opinion of the Court
OPINION
Hall, Judge:
This case is before the Court on respondent’s motion for summary judgment filed pursuant to Rule 121, Tax Court Rules of Practice and Procedure.
At the time they filed their petition, petitioners resided in Oelwein, Iowa. Respondent determined deficiencies in petitioners’ 1975 and 1976 income tax of $1,019.10 and $909.84, respectively. The sole issue in this case is whether petitioners are subject to the self-employment tax imposed by section 1401.1
Petitioners make no assertions, which, if proved, would establish either that they are not subject to the self-employment tax…
2Cases cited41 opinions
- Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
- Simon v. Eastern Kentucky Welfare Rights OrganizationSupreme Court of the United States · 1976
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Bolling v. SharpeSupreme Court of the United States · 1954
- Blonder-Tongue Laboratories, Inc. v. University of Illinois FoundationSupreme Court of the United States · 1971
36 more not listed; retrieve them via the Exa API.
3Cited by27 opinions
- Wright v. CommissionerUnited States Tax Court · 1985
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Vallone v. CommissionerUnited States Tax Court · 1987
- Estate of Reis v. CommissionerUnited States Tax Court · 1986
- Bunce v. United StatesUnited States Court of Federal Claims · 1993
22 more not listed; retrieve them via the Exa API.