Average Comp for 415 purposes

sole-prop, activity commenced late in 2021, 2021 Schedule C is negative, 2022 sch C is 150K, 2023 Sch C is 150K.  What is my 3 year average comp for 415 limit purposes?  Is it 150K or is it 100K?  Is there any specifc guidance on that type of situation?

I vote for $100K.  Since he had "activity" in 2021 I think it counts in the average.  Are you counting that as a Year of Service for 415 purposes? 

What justification would there be to exclude it?  

counting sevice should be consistent with the average comp calculations.  For the 100K answer - yes, for 150K answer no.

I would say $100,000 as well - but not actually because you have to adjust those $150k years for the 50% SECA tax deduction.

sorry guys, answering my own silly question.  Mathematically it actually does not matter since the answer is the same.  (0 + x +y) / 3 * 3/10 is the same as (x + y) / 2 x 2/10; I am assuming everyone agrees that service and comp treatment should be consistent.

Right, the only way you get $150k average is with a denominator of two years of service, but as there was business activity in that first year (even though a loss/negative income) it is still service.