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OPINION
DAWSON, Judge: Respondent determined deficiencies in
petitioners' Federal income taxes for the taxable years 1990 and
1991 in the amounts of $2,837 and $2,837.48, respectively.
At issue is whether termination payments received by William
R. Jackson, a former independent agent for State Farm Insurance
Companies, are subject to self-employment tax pursuant to
sections 1401 and 1402.1
This case was submitted fully stipulated under Rule 122.
The stipulation of facts and attached exhibits are incorporated
herein by this reference. The pertinent facts are summarized
below.
Petitioners resided in Lakeshore, Mississippi, at the time
they filed their petition in this case.
On April 15, 1954, William R. Jackson (petitioner) was
appointed as an exclusive agent of State Farm Insurance Companies
(State Farm), which consisted of the following four subcompanies:
(1) State Farm Mutual Automobile Insurance Co.; (2) State Farm
Life Insurance Co.; (3) State Farm Fire & Casualty Co.; and (4)
State Farm General Insurance Co.
1 Unless 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.
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Last modified: May 25, 2011