Paul B. and Jane C. Ding - Page 5

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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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