Legal Opinion

Anderson v. Commissioner

United States Tax Court

Decided March 4, 1992No. Docket Nos. 29293-88, 7750-90Unpublished

Petitioners H and W each hold a 25-percent interest in a general partnership. In addition to her distributive share of the partnership's trade or business income, W received guaranteed payments for services rendered. Petitioners argue that only the guaranteed payments constitute self-employment income. R contends that the entire amount received represents W's distributive share of the partnership's taxable income and therefore is subject to self-employment tax.

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Petitioners H and W each hold a 25-percent interest in a general partnership. In addition to her distributive share of the partnership's trade or business income, W received guaranteed payments for services rendered. Petitioners argue that only the guaranteed payments constitute self-employment income. R contends that the entire amount received represents W's distributive share of the partnership's taxable income and therefore is subject to self-employment tax. Held, under sec. 1402(a), I.R.C., net earnings from self-employment includes W's distributive share of partnership trade or business…

1Opinion of the Court

BARBARA C. AND RAYMOND H. ANDERSON, JR., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Anderson v. Commissioner

Docket Nos. 29293-88, 7750-90

United States Tax Court

T.C. Memo 1992-130; 1992 Tax Ct. Memo LEXIS 153; 63 T.C.M. (CCH) 2278; T.C.M. (RIA) 92130;

March 4, 1992, Filed

Decisions will be entered under Rule 155.

Petitioners H and W each hold a 25-percent interest in a general partnership. In addition to her distributive share of the partnership's trade or business income, W received guaranteed payments for services rendered. Petitioners argue that only the guaranteed payments…

2Cases cited12 opinions

  1. Neely v. CommissionerUnited States Tax Court · 1985
  2. Bixby v. CommissionerUnited States Tax Court · 1972
  3. Carlos and Jacqueline Marcello v. Commissioner of Internal Revenue, Joseph, Jr. And Anastasia Marcello v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1967
  4. Enoch v. CommissionerUnited States Tax Court · 1972
  5. United States v. LombardoSupreme Court of the United States · 1916

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