IRC Sec. 1401(a) imposes a tax on an individual’s Net Earnings Self-employment (NESE). However, under IRC Sec. 1402(a)(1) , “net rental income” generally isn’t included in NESE, unless (1) the income is received by a “real estate dealer,” or (2) the rent includes substantial services provided to the occupant for the occupants’ convenience. In a Chief Counsel Advice (CCA), two examples were given differentiating the level of owner participation for inclusion as NESE. In the first example, the Chief Counsel considered the level of services noting that the occupants were not required to maintain the space in a condition for occupancy, and the substantial services provided by the owner were substantial and therefore their rental income was included in NESE. In the second example, the owner provided a room and bathroom and the taxpayer only cleaned in between renters so income was not included as NESE.