- 11 - element to which respondent directs our attention, viz: “(ii) the amount of the taxpayer’s net earnings from self-employment for the taxable year (within the meaning of section 1402(a)).” Analysis From its 1971 origin through its 1977 revision, until TRA 1986, the earned income limitation on the standard deduction was statutorily defined by reference to section 911. In TRA 1986, the Congress chose to remove the reference to section 911 and to not put any other definition in its place. Ordinarily, we would expect that a change in statutory language indicates a change in meaning. Robinson v. Commissioner, 119 T.C. 44, 61-62 (2002) (and cases there cited). We have not found anything in the legislative history to lead us to any different conclusion in this matter. Compare Robinson v. Commissioner, 119 T.C. at 62 n.11. Accordingly, we conclude that “earned income” in section 63(c)(5)(B) means something different from “earned income (as defined in section 911(b))”. Section 32 was amended by several provisions of TRA 1986,7 including several provisions in the same title of TRA 1986 that revised section 63(c)(5). When section 63(c)(5) was revised, the Congress could have, but did not choose to, incorporate the section 32 language, or reference section 32, or use other 7 Sec. 32 was amended by secs. 104(b)(1)(B), 111 (5 places), 1272(d)(4), and 1301(j)(8) of TRA 1986.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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