Legal Opinion

Henson v. Commissioner

United States Tax Court

Decided August 5, 1976No. Docket Nos. 8283-74, 296-75PublishedCited by 69 opinions

Petitioner, a devotee of Sai Baba, is opposed to life, retirement, and medical insurance on religious grounds. Held: Petitioner is not exempt from the tax on self-employment income under sec. 1402(h), I.R.C. 1954. The exemption provisions of sec. 1402(h) are not unconstitutionally narrow in scope.

1Opinion of the Court

OPINION

Drennen, Judge:

Respondent determined deficiencies in petitioner’s income tax for the years 1972 and 1973 in the respective amounts of $226 and $681. The sole issue presented is whether petitioner is liable for the tax on self-employment income under sections 1401 and 1402,1.R.C. 1954,2 for the years at issue.

All of the facts have been stipulated and are summarized below. The stipulation of facts together with exhibits attached thereto are incorporated herein by this reference.

Petitioner Julia C. Henson maintained her legal residence in Los Angeles, Calif., at the time of filing the…

2Cases cited3 opinions

  1. Carmichael v. Southern Coal & Coke Co.Supreme Court of the United States · 1937
  2. Palmer v. CommissionerUnited States Tax Court · 1969
  3. Abney v. CampbellCourt of Appeals for the Fifth Circuit · 1953

3Cited by69 opinions

  1. United States v. LeeSupreme Court of the United States · 1982
  2. Robert Shelton Jaggard and Marybeth Jaggard v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1978
  3. Liberty University, Inc. v. Jacob LewCourt of Appeals for the Fourth Circuit · 2013
  4. In Re Jacob R. Ward v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1979
  5. Jaggard v. CommissionerUnited States Tax Court · 1981

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