Allyson Christina Briggs - Page 8

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                    SEC. 32.  EARNED INCOME.                                          
                           *    *    *    *    *    *    *                            
                    (c) Definitions and Special Rules.--For purposes of               
               this section--                                                         
                           *    *    *    *    *    *    *                            
                         (2) Earned income.                                           
                              (A) The term “earned income” means--                    
                                   (i)  wages, salaries, tips, and other              
                              employee compensation, but only if such                 
                              amounts are includible in gross income for              
                              the taxable year, plus                                  
                                   (ii) the amount of the taxpayer’s net              
                              earnings from self-employment for the taxable           
                              year (within the meaning of section 1402(a)),           
                              but such net earnings shall be determined               
                              with regard to the deduction allowed to the             
                              taxpayer by section 164(f).                             
               Petitioner correctly points out that “earned income” in                
          section 32 is defined in the statute (sec. 32(c)(2)(A)(ii)) to              
          include the concept of net earnings from self-employment, but               
          there is no such definition of “earned income” in section 63.               
               We agree with petitioner’s conclusion.                                 
               The Table Is Set; The Tax Reform Act of 1969                           
               Section 802 of the Tax Reform Act of 1969 (TRA 1969), Pub.             
          L. 91-172, 83 Stat. 487, 676, significantly increased the                   
          standard deduction available to taxpayers who did not itemize               
          deductions.                                                                 
               Section 804 of TRA 1969 (83 Stat. at 685) added section                
          1348, which provided a 50-percent maximum rate on earned income,            





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