108 T.C. No. 10
UNITED STATES TAX COURT
WILLIAM R. AND MURIEL G. JACKSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23558-94. Filed March 31, 1997.
P, a former insurance agent for State Farm
Insurance Companies, received termination payments
after his retirement on December 31, 1987, pursuant to
the terms of an independent contractor Agent's
Agreement. Held, the termination payments P received
were not "derived" from a trade or business carried on
by him as an insurance agent during 1990 and 1991.
Therefore, such payments are not subject to self-
employment tax under sections 1401 and 1402, I.R.C.,
and P is not liable for such tax. Milligan v.
Commissioner, 38 F.3d 1094 (9th Cir. 1994), revg. T.C.
Memo. 1992-655, followed.
William R. Jackson, pro se.
John F. Driscoll, for respondent.
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