Robert Schelble and Susan Schelble - Page 2

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          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.                                                                         




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