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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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