Allyson Christina Briggs - Page 11

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          section 141(e) to section 63(e).  The method of calculating the             
          amount of the limitation also was revised.  However, the earned             
          income definition continued to be “earned income (as defined in             
          section 911(b)).”                                                           
               The Tax Reform Act of 1986                                             
               The Tax Reform Act of 1986 (TRA 1986), Pub. L. 99-514, 100             
          Stat. 2085, eliminated the ZBA.  Section 102(a), TRA 1986, 100              
          Stat. at 2099, revised section 63 to accomplish that change as              
          well as numerous other changes.  As may be seen supra note 3, the           
          revision of the dependent taxpayer rule continues the term                  
          “earned income”, but eliminates the reference to section 911 and            
          does not provide any replacement definition.                                
               Section 32                                                             
               Respondent urges us to follow the approach of section 32.              
          As to trade or business income, section 911 focuses on                      
          compensation for personal services, while section 32 deals with             
          “net earnings from self-employment”.                                        
               Section 32, the earned income credit, was initially enacted            
          as section 436 by section 204(a) of the Tax Reduction Act of                
          1975, Pub. L. 94-12, 89 Stat. 26, 30-31.  Subsection                        
          (c)(2)(A)(ii) of then-new section 43, in defining “earned income”           
          for purposes of the earned income credit, included the same                 

               6  Sec. 43 was renumbered as sec. 32 by sec. 471(c)(1) of              
          the Deficit Reduction Act of 1984, Pub. L. 98-369, 98 Stat. 494,            
          826.                                                                        





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