Allyson Christina Briggs - Page 12

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          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)).”                  
               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.                            

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