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distributed, of income or loss (as described in section
702(a)(8)) from any trade or business carried on by a partnership
in which the individual is a partner. Sec. 1402(a). The statute
makes a distinction between general and limited partners. Other
than certain guaranteed payments (described in section 707(c))
made to a limited partner by a partnership, a limited partner's
distributive share of the partnership's items of income or loss
is excluded from the definition of net earnings from self-
employment. Sec. 1402(a)(13). Briefly stated, income derived by
an individual from carrying on a trade or business through a sole
proprietorship or as a partner (other than a limited partner) in
a partnership generally constitutes net earnings from self-
employment. Sec. 1.1402(c)-1, Income Tax Regs.
The parties agree that the items attributable to
petitioner's sole proprietorships and the partnership were
properly included in the computation of petitioner's net earnings
from self-employment for each year. They disagree over the
treatment of the pass-through items from the S corporations and,
although petitioners presented no argument on the point,
apparently disagree over the treatment of the carryover loss with
respect to 1992.
S Corporation Pass-Through Items
Neither section 1402, which provides the definition of net
earnings from self-employment, nor the regulations promulgated
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