Estate of Frank Johnson - Page 171




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          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 for            






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