Edgar L. and Joan H. Parker - Page 1

                                 T.C. Memo. 2002-305                                  

                               UNITED STATES TAX COURT                                

                     EDGAR L. AND JOAN H. PARKER, Petitioners v.                      
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5732-01.              Filed December 16, 2002.              

                    P, self-employed, worked under contract as a                      
               district manager for F, a group of insurance companies.                
               F canceled P’s contract and paid P an amount designated                
               “Contract Value”, based on the quantity (length of                     
               service) and quality (final 6 months’ earnings) of the                 
               services rendered by P to F.  P failed to pay self-                    
               employment tax with respect to the Contract Value,                     
               claiming that it constituted a capital gain.                           
                    Held:  The contract value is subject to the tax on                
               self-employment income and is not capital gain.                        

               Robert B. Alexander, for petitioners.                                  
               Donna M. Palmer, for respondent.                                       

Page:   1  2  3  4  5  6  7  8  9  10  11  12  Next

Last modified: May 25, 2011