- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011