- 117 - from self-employment” is defined as “the 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”. Sec. 1402(a). Respondent determined self-employment taxes on the basis of petitioner’s income from his real estate business. The applicable percentage for each of the tax years at issue was applied to the maximum amount of self-employment earnings subject to self-employment tax: $39,600 in 1985, $42,000 in 1986, $43,800 in 1987, and $45,000 in 1988. See sec. 1402(b)(1). Respondent determined petitioner’s self-employment tax liability to be $4,67373 for 1985, $5,16674 for 1986, $5,38775 for 1987, and $5,85976 for 1988. Petitioner was engaged in the trade or business of buying and selling real estate during the years at issue. He does not contest on brief that his earnings from that business are subject to self-employment taxes. Therefore, we sustain respondent’s 73Self-employment tax ($4,673) = Maximum amount subject to self-employment tax ($39,600) x Applicable percentage (.118). 74Self-employment tax ($5,166) = Maximum amount subject to self-employment tax ($42,000) x Applicable percentage (.123). 75Self-employment tax ($5,387) = Maximum amount subject to self-employment tax ($43,800) x Applicable percentage (.123). 76Self-employment tax ($5,859) = Maximum amount subject to self-employment tax ($45,000) x Applicable percentage (.1302).Page: Previous 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 Next
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