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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.
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