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ambit of “disqualified income” under section 32(i) and exceeds
the threshold amount ($2,200).3 Accordingly, petitioner is not
entitled to claim an EIC.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
3 We note that the phrase “not derived in the ordinary course”
also appears in sec. 469(e), which deals with portfolio income in
the context of the passive loss rules. These types of portfolio
income include income that would be disqualified income. See
sec. 1.469-2T(c)(3)(ii), Temporary Income Tax Regs., 53 Fed. Reg.
5713 (Feb. 25, 1988).
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