- 2 - capital assets from the sale of petitioner's insurance agency or are self-employment income subject to the self-employment tax under sections 14012 and 1402. We hold that the payments are self-employment income subject to self-employment tax. This matter was submitted to the Court fully stipulated pursuant to Rule 122. The stipulation of facts and the exhibits attached thereto are incorporated by this reference. At the time the petition was filed, petitioners resided in Fort Collins, Colorado. On March 13, 1973, petitioner executed a Career Agent's Agreement (the Agreement) with American Family Life Insurance Co., American Family Mutual Insurance Co., and American Standard Insurance Co. of Wisconsin (collectively the Companies). The Companies' principal office was at Madison, Wisconsin. According to the Agreement, an insurance agent of the Companies could be eligible for "extended earnings" when the Agreement was terminated. Aside from certain paperwork and reporting requirements, the elements which must be satisfied under the Agreement in order for an agent to qualify for extended earnings are: (a) Within 10 days of termination, the agent must return to the Company all policies and policy records, manuals, materials, advertising and supplies or other property of the 2All 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, unless otherwise indicated.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011