- 99 - the self-employment tax for each of those years to the extent of her net earnings from self-employment. G. Self-Employment Deduction For 1990, section 164(f) provides a deduction for one-half of the taxes imposed by section 1401 for such year. Respondent contends that petitioners are entitled to increase their self- employment tax deduction for 1990 in the amount of $7,301. Petitioners contend that respondent is incorrect. This item is a computational adjustment and must be recalculated to reflect our holding in the instant cases that Frank and Katherine understated their 1990 income by $92,306, and that only Katherine is liable for the self-employment tax imposed by section 1401 for that year. H. Married Couples Deduction Respondent contends that Frank and Katherine are entitled to a $3,000 married couples deduction for the years 1983 through 1986. Petitioners contends that Frank was retired for all of those years; therefore, Frank and Katherine are not entitled to a married couples deduction for any year in issue. We agree with petitioners. In the case of a joint return for 1983 through 1986, section 221 allows a deduction for two-earner married couples equal to 10 percent of the lesser of $30,000 or the “qualified earned income” of the spouse with the lower qualified earned income forPage: Previous 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 106 107 108 Next
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