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need not engage in an extended discussion to dispose of this
case.
Section 1401 imposes a tax on “the self-employment income of
every individual”. Section 1402(b) defines self-employment
income as “the net earnings from self-employment”. Section
1402(a) defines self-employment earnings as “gross income derived
by an individual from any trade or business carried on by such
individual, less the deductions * * * which are attributable to
such trade or business”. Gain or loss from the sale or exchange
of capital assets or from the disposition of other property
(except for stock in trade, inventory, or property held primarily
for sale to customers in the ordinary course of business) is
excluded from the computation of net earnings from self-
employment. Sec. 1402(a)(3)(A), (C).
In Newberry v. Commissioner, 76 T.C. 441, 444 (1981), we
held that, for income to be taxable as self-employment income,
“there must be a nexus between the income received and a trade or
business that is, or was, actually carried on.” In order to
satisfy the nexus standard, the “income must arise from some
actual (whether present, past, or future) income-producing
activity”. Id. at 446.
During the 11-plus years that petitioner was a district
manager for the companies, his business consisted principally of
recruiting, training, and supervising insurance agents, and he
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