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DING v. C.I.R.

No. 98-70848.

200 F.3d 587 (1999)

Paul B. DING; Jane C. Ding, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Filed December 30, 1999.

Attorney(s) appearing for the Case

Paul B. Ding and Jane C. Ding, Pro Se, Garden Grove, California, for the petitioners-appellants.

Loretta C. Argrett, Assistant Attorney General, Washington, D.C.; David I. Pincus and Sara Ann Ketchum, United States Department of Justice, Washington, D.C., for the respondent-appellee.

Before: BROWNING, RYMER, and KLEINFELD, Circuit Judges.

RYMER, Circuit Judge:

The question before us is whether pass-through items from Subchapter S corporations (S corporations) can be included in determining self-employment tax liability under § 1402(a) of the Internal Revenue Code.

Taxpayers Paul and Jane Ding appeal from the tax court's determination that they were not entitled to deduct pass-through losses from two S corporations for purposes of calculating their...

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