McAllister v. Commissioner
United States Tax Court
Held, petitioners are subject to self-employment tax on self-employment income derived from their citrus grove farming operations for the taxable years 1958, 1959, and 1960 under the provisions of sections 1401 and 1402 of the Internal Revenue Code of 1954, as amended.
1Opinion of the Court
Arundell, Judge:
Respondent determined deficiencies in income tax (tax on self-employment income under chapter 2 of subtitle A of the 1954 Code, as amended) for the calendar years 1958, 1959, and 1960 in the amounts of $288.50, $360, and $432, respectively.
The only issue is whether petitioners are subject to the tax on self-employment income provided for in chapter 2 of subtitle A of the 1954 Code, sections 1401 and 1402, as amended.
FINDINGS OF FACT
Petitioners are husband and wife. During the taxable years 1958, 1959, and 1960 they resided in Orlando, Fla. They filed their joint Federal income…
2Cases cited3 opinions
- Henderson v. FlemmingCourt of Appeals for the Fifth Circuit · 1960
- Nannie D. Harper v. Arthur S. Flemming, Secretary of the Department of Health, Education and WelfareCourt of Appeals for the Fourth Circuit · 1961
- Clarke v. CommissionerUnited States Tax Court · 1957
3Cited by4 opinions
- Richard J. Bot Phyllis Bot v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 2003
- McAllister v. CommissionerUnited States Tax Court · 1964
- Nelsen v. CommissionerUnited States Tax Court · 1993
- Richard J. Bot v. Internal RevenueCourt of Appeals for the Eighth Circuit · 2003