of unemployment compensation includable in gross income is equal to the lesser of one-half of the amount of the excess of such sum over the base amount, or the amount of the unemployment compensation. Petitioner’s base amount equals $12,000. See sec. 85(b)(1). Petitioner argues that the unemployment compensation he received is not taxable under section 85 because his adjusted gross income in 1984 fell below his base amount of $12,000. Our determination that petitioner is not entitled to any deductions or an investment tax credit with respect to his dealings with Encore and that he is not entitled to a business bad debt deduction in connection with Carter results in an upward adjustment in petitioner’s adjusted gross income for 1984, bringing him over the base amount of $12,000. Accordingly, the $5,312 petitioner received in unemployment compensation is includable in his gross income for 1984. We sustain respondent’s determination on this issue. Issue 4. Self-Employment Tax Section 1401 imposes a self-employment tax on the self- employment income of every individual. Individuals whose net self-employment income equals or exceeds $400 during the taxable year are required to report such income. Sec. 6017. Petitioner argues that his net self-employment income did not exceed $400 in 1984. We have determined, however, that petitioner is not entitled to various claimed deductions, causing petitioner’s netPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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