- 2 - determinations are no longer disputed.1 The issue remaining for decision is whether petitioners are liable for self-employment tax under section 14012 on value-added payments that Eric Fultz (Mr. Fultz) received from an agricultural cooperative. We hold the value-added payments are subject to the self-employment tax. FINDINGS OF FACT Some of the facts have been stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Petitioners, husband and wife, resided in Tracy, Minnesota, at the time their petition was filed. During all relevant years, Mr. Fultz was a farmer and ran a farm operation involving grain and livestock. Sandra Fultz (Mrs. Fultz) was a store manager. 1. Fultz Farms, Inc. Fultz Farms, Inc. (Fultz Farms), was incorporated in December 1990 by Bernard Fultz, Mr. Fultz’s father. During the years at issue, petitioners owned approximately 470 acres of farm 1Respondent has conceded an adjustment in “1.A. AG Rent-SE Income” for 1994 and 1995, along with the corollary and computational adjustments associated with that adjustment. In addition, petitioners presented no argument nor provided any evidence with regard to adjustments “1.B. Dividends” or “1.D. Patronage Dividends” for either year and therefore have conceded those adjustments. 2Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. All dollar amounts are rounded.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011