Barry Philliip Fiegel - Page 4




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          amount of $10,491.  See sec. 1401.  Accordingly, petitioner is              
          also entitled to a deduction in the amount of one-half of the               
          self-employment tax, as stated by respondent in the notice of               
          deficiency.  See sec. 164(f)(1).                                            
               Finally, respondent made a computational adjustment                    
          disallowing petitioner’s claimed earned income credit.  The                 
          record does not establish that petitioner had any qualifying                
          children, as defined under section 32(c)(3), during taxable year            
          1996.  Because petitioner’s earned income was greater than $9,500           
          during that year, petitioner was not eligible to claim the                  
          credit.  See sec. 32(a)(2).                                                 
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          
























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