Randolph v. Commissioner
United States Tax Court
Petitioners, active members of the Seventh Day Adventist Church, believe that any participation in the Social Security program violates the tenets of their religion. Held, petitioner Stella Randolph is not collaterally estopped from contesting this deficiency because this Court decided the principal issue against Ronald E. Randolph in Randolph v. Commissioner, T.C. Memo. 1969-289, a proceeding in which she was not a party.
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Petitioners, active members of the Seventh Day Adventist Church, believe that any participation in the Social Security program violates the tenets of their religion. Held, petitioner Stella Randolph is not collaterally estopped from contesting this deficiency because this Court decided the principal issue against Ronald E. Randolph in Randolph v. Commissioner, T.C. Memo. 1969-289, a proceeding in which she was not a party. Held, further: Petitioners are not exempt from the tax on self-employment income under sec. 1402(h), I.R.C. 1954. (a) The tax does not violate the taking clause of the…
1Opinion of the Court
Drennen, Judge:
Respondent determined the following deficiencies in petitioners’ income tax:
1974 rfS OO M
1975 ^ -d Cl
1976 cn Os H
After concessions, the issues remaining for decision are:(1) Whether petitioners are liable for the tax on their self-employment income under the provisions of sections 1401 and 1402, I.R.C. 1954;1 and(2) Whether petitioners are entitled to a deduction for automobile expenses in excess of those allowed by respondent for the 1974 taxable year.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulation of facts together with the exhibits…
2Cases cited24 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. SunnenSupreme Court of the United States · 1948
- Commissioner v. FlowersSupreme Court of the United States · 1946
- Carmichael v. Southern Coal & Coke Co.Supreme Court of the United States · 1937
- Automobile Club of Mich. v. CommissionerSupreme Court of the United States · 1957
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3Cited by20 opinions
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- Baylis v. CommissionerUnited States Tax Court · 1982
- Carsendino v. CommissionerUnited States Tax Court · 1994
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