Orin F. Farnsworth and Mary L. Farnsworth - Page 2




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          F. Farnsworth under his District Manager’s Appointment Agreement            
          (DMAA) with Farmers Insurance Group, and (2) whether petitioners            
          are liable for self-employment tax under section 14011 on the               
          DMAA “contract value” termination payments.                                 
               We hold that petitioners are not entitled to exclude from              
          income any portion of the DMAA “contract value” termination                 
          payments because petitioners failed to prove that Mr. Farnsworth            
          had any basis in the DMAA contract.  We further hold that the               
          DMAA “contract value” termination payments included in                      
          petitioners’ income are subject to self-employment tax under                
          section 1401.                                                               
                                  FINDINGS OF FACT                                    
               Most of the facts have been stipulated and are so found.               
          The stipulation of facts and related exhibits are incorporated by           
          this reference.                                                             
               Petitioners were residents of Redding, California, when they           
          filed their petition.  Petitioners are married and filed a joint            
          Federal income tax return, Form 1040, U.S. Individual Income Tax            
          Return for the taxable year 1995.                                           






               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code in effect for the year at issue, and              
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  





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