9 Furthermore, petitioner could not recall what the largest expense, repairs and maintenance, represented. Based upon our review of the relevant factors, we find that petitioner was compensated as an independent contractor by Astron during 1993. Therefore, petitioner's net earnings therefrom are subject to self-employment tax. Respondent is sustained on this issue. Social Security Benefits Section 86(a) provides that gross income includes Social Security benefits in the amount equal to the lesser of: (1) One half of the Social Security benefits received during the year; or (2) one-half of the excess of the sum of (a) modified adjusted gross income and (b) plus one-half of the Social Security benefits received over the base amount. The base amount for taxpayers filing a joint return for 1993 is $32,000. Sec. 86(c)(1)(B). For 1993, petitioner's modified adjusted gross income equals adjusted gross income. See sec. 86(b)(2). Petitioner argues that the calculation pursuant to section 86 does not result in the inclusion of any Social Security benefits in income for 1993. The sum of one-half of the Social Security benefits received, $10,687, and modified adjusted gross income for 1993, $32,251,5 equals $42,928. This amount exceeds 5 This includes additional wage income of $170 and allowing a deduction of $2,096 for one-half of the self-employment taxes determined by respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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