United States Tax Court October 13, 2004, No. 21529-03 (Olson v. Comm'r)

T.C. Memo. 2004-234

UNITED STATES TAX COURT

GREG OLSON, Petitioner v.

COMMISSIONER OF INTERNAL REVENUE, Respondent

Docket No. 21529-03. Filed October 13, 2004.

Respondent determined deficiencies and additions

to tax for petitioner’s 1999 and 2000 taxable years.

Held: Petitioner received taxable income during

1999 and 2000, and a portion thereof is subject to

self-employment tax. Sec. 861, I.R.C.