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1402(a) provides that the term "net earning from self-employment"
means the gross income derived by an individual from any trade or
business carried on by such individual less any allowable
deductions.
Section 1.219-1(c)(1), Income Tax Regs., defines
compensation as wages, salaries, professional fees, or other
amounts derived from personal services actually rendered but does
not include amounts, such as interest and dividends, derived from
or received as earnings or profits from property. See Miller v.
Commissioner, 77 T.C. 97 (1981).
Petitioner contends that he received $7,893 of
"compensation" during 1993 consisting of an IRA distribution in
the amount of $2,900, dividend income in the amount of $4,640,
and capital gain in the amount of $353. In this regard, he
contends that Congress did not intend to exclude dividend income,
capital gain, and IRA distributions from the definition of
"compensation" for purposes of section 219(a). Petitioner
asserts that by using the term "includes" in the definition of
"compensation" under section 219(f), Congress did not mean to
exclude other unlisted sources of income, such as dividends or
capital gain. He makes a similar contention with respect to the
use of the term "means" in section 401(c)(2).
Petitioner's contentions were considered in Miller v.
Commissioner, supra. In that case, the taxpayer claimed
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