Paul B. and Jane C. Ding - Page 4

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          loss.  They included the carryover loss in the computation of               
          petitioner's 1992 self-employment tax.  Once again they reported            
          that petitioner had negative net earnings from self-employment              
          and no self-employment tax liability.                                       
               In the notice of deficiency respondent determined that                 
          petitioner's self-employment tax liability for each year must be            
          computed by taking into account only:  (1) The net profits and              
          losses attributable to petitioner's sole proprietorships; and (2)           
          the partnership loss.  Implicit in respondent's determination is            
          the disallowance of the pass-through items from the S                       
          corporations and the carryover loss from 1991 to 1992.  Other               
          adjustments in petitioners' favor were also made in the notice of           
          deficiency and are either not in dispute or will be resolved in             
          accordance with the determination of petitioner's self-employment           
          tax liability for each year.                                                
                                       OPINION                                        
               In addition to other taxes, an individual's self-employment            
          income is subject to a self-employment tax.  Sec. 1401.  Subject            
          to irrelevant exclusions, self-employment income means net                  
          earnings from self-employment.  Sec. 1402(b).  Net earnings from            
          self-employment generally include gross income derived from any             
          trade or business carried on by the individual, less allowable              
          deductions attributable to such a trade or business, plus the               
          individual's distributive share, if any and whether or not                  





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