Case: Minnesota Chippewa Tribe Members Not Exempt From Self-Employment Tax, Tax Court Decision Affirmed (8th Cir.)

Taxpayer, a member of the Minnesota Chippewa Tribe who operates a law practice, is subject to taxation on his self-employment income because no act or treaty exempts him from federal taxation, the U.S. Court of Appeals for the Eighth Circuit held, affirming the U.S. Tax Court’s ruling. For the 2016 and 2017 tax years, Taxpayer reported net operating loss carryforwards which exceeded his income, and the IRS sent a notice of determination to collect self-employment taxes on such income. Taxpayer argued that his income was exempt from self-employment taxes because “Indians are generally exempt from federal taxes,” or, alternatively, that ...