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petitioner's net earnings from self-employment eliminates the
carryover loss. Accordingly, we hold that petitioner's 1992 net
earnings from self-employment must be computed without taking
into account any carryover loss from 1991.
On brief respondent concedes that certain of the fees paid
by the S corporations and reflected on the Schedules C for Ding
Trading for the years in issue constitute wages and not earnings
from self-employment. Consequently, respondent no longer claims
any section 1401 tax attributable to those amounts.
To reflect the foregoing,
Decision will be
entered under Rule 155.
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Last modified: May 25, 2011