Research Problem

Max Coen is employed as a full-time police officer by the Memphis Police Department. He is required to abide by the department’s rules of conduct, which apply whether he is on-duty or off-duty. With the department’s permission, Max “moonlights” as a security guard for several public school districts. While serving as a security guard, he is required to wear his police uniform and to carry police equipment (gun, handcuffs, etc.). The school districts pay security guards on an hourly basis and do not withhold income tax or payroll tax. This year, Max earned a $32,000 salary from the city of Memphis and $8,100 wages from the school districts. Do Max’s wages constitute net earnings from self-employment on which he must pay SE tax?