Walter L. Medlin - Page 29

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          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).              






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