Edgar L. and Joan H. Parker - Page 7




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          need not engage in an extended discussion to dispose of this                
          case.                                                                       
               Section 1401 imposes a tax on “the self-employment income of           
          every individual”.  Section 1402(b) defines self-employment                 
          income as “the net earnings from self-employment”.  Section                 
          1402(a) defines self-employment earnings as “gross income derived           
          by an individual from any trade or business carried on by such              
          individual, less the deductions * * * which are attributable to             
          such trade or business”.  Gain or loss from the sale or exchange            
          of capital assets or from the disposition of other property                 
          (except for stock in trade, inventory, or property held primarily           
          for sale to customers in the ordinary course of business) is                
          excluded from the computation of net earnings from self-                    
          employment.  Sec. 1402(a)(3)(A), (C).                                       
               In Newberry v. Commissioner, 76 T.C. 441, 444 (1981), we               
          held that, for income to be taxable as self-employment income,              
          “there must be a nexus between the income received and a trade or           
          business that is, or was, actually carried on.”  In order to                
          satisfy the nexus standard, the “income must arise from some                
          actual (whether present, past, or future) income-producing                  
          activity”.  Id. at 446.                                                     
               During the 11-plus years that petitioner was a district                
          manager for the companies, his business consisted principally of            
          recruiting, training, and supervising insurance agents, and he              






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