- 6 - 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).Page: Previous 1 2 3 4 5 6 7
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