- 29 - not excludable under section 1402(a)(2) in calculating petitioners’ net earnings from self-employment. IV. Conclusion We find that petitioners were engaged in the business of acquiring, marketing, and selling corn and corn products during 1994 and 1995, and that they derived the value-added payments from that business. We hold, therefore, that the value-added payments of $132,375 and $207,612 in 1994 and 1995, respectively, reduced by petitioners’ acquisition costs of $18,070 and $16,431, respectively, constitute petitioners’ net earnings from self-employment under section 1402. However, because respondent did not move for an increased deficiency in this case, any deficiency determined as a result of this opinion may not exceed the deficiencies determined in the notice of deficiency. We have considered the parties’ other arguments and, to the extent not herein discussed, find them to be without merit. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29
Last modified: May 25, 2011