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discussion by the Court as to the reasoning and rational behind
this holding other than citing * * * [section 1402(a)(5)(A)] and
the related Treasury Regulation.” We agree that there are
factual distinctions between this case and Webb. However, it
would serve little purpose to discuss those distinctions in
detail because we find that none is of any consequence.
Furthermore, we think the language of section 1402(a)(5)(A) is
sufficiently clear so that reference to the statute is all that
was necessary in that case, as it is in this case, to support its
application.
On brief, petitioner invites us to ignore several other
cases that support respondent’s determination because “none * * *
take into account * * * the practical aspects of how to treat
such an attribution of income * * * [to a married individual who
files a separate] tax return.” Except as provided by section
6017,4 however, we fail to see how the filing status of the
taxpayer makes any difference for purposes of section
1402(a)(5)(A).
In accordance with the provisions of section 1402(a)(5)(A)
petitioner must take into account all of the income and
4 Sec. 6017 states, in relevant part: “In the case of a
husband and wife filing a joint return * * * [the self-employment
tax] shall not be computed on the aggregate income but shall be
the sum of the [self-employment] taxes computed * * * on the
separate self-employment income of each spouse.” The concept of
“separate self-employment income of each spouse” in sec. 6017 is
entirely consistent with sec. 1402(a)(5)(A).
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