William R. and Muriel G. Jackson - Page 2

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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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