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“proceeds” is proceeds after subtraction of operating expenses.
See, e.g., Atl. Mut. Ins. Co. v. Commissioner, 523 U.S. 382
(1998); Hedden v. Richard, 149 U.S. 346, 348-349 (1893); Central
Reserve Life Corp. v. Commissioner, 113 T.C. 231, 237 (1999) (it
is appropriate to construe the meaning of section 816 of
subchapter L of the Code, involving insurance companies, in light
of its usage in the insurance industry, to the extent it has an
established meaning in that industry).
The term “proceeds”, as a “word of great generality”, see
Phelps v. Harris, supra at 380, refers to a general class that
encompasses a collection of all forms of proceeds, including
gross proceeds, net proceeds, and any other property received
from an exchange of property, etc. As a matter of formal logic,
proceeds from the sale of the catch of fish determined after
subtraction of operating expenses is completely included in the
greater class, proceeds from the sale of the catch; that is, net
proceeds is a form of or subclass of proceeds. See Langer, An
Introduction to Symbolic Logic 115-118 (3d ed. 1967).
b. Legislative History and Congressional Intent Underlying
Section 3121(b)(20) and the Development of Section
31.3121(b)(20)-1(a), Employment Tax Regs.
Petitioners argue section 3121(b)(20) precludes self-
employment status for fishing boat workers who receive proceeds
after subtraction of operating expenses because those operating
expenses do not depend “solely” on the amount of the catch, as
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