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NOTES 195 Tax Lawyer, Vol. 54, No. 1 NOTE S CORPORATION LOSSES MAY NOT BE DEDUCTED FROM SELF-EMPLOYMENT NET INCOME: DING V. COMMISSIONER In Ding v. Commissioner1 the Ninth Circuit held that an individual cannot take into account S corporation pass-through losses for purposes of determining self-employment tax liability.2 In making its determination, the court focused on the section 1402 definition of self-employment net income, as interpreted by Revenue Ruling 59-221.3 The Ding II decision raises...