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original determinations are no longer disputed.1 The issue
remaining for decision is whether petitioners are liable for
self-employment tax under section 14012 on value-added payments
that they received from an agricultural cooperative. We hold the
value-added payments are subject to the self-employment tax.
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of
facts and the attached exhibits are incorporated herein by this
reference. Petitioners, husband and wife, resided in Tracy,
Minnesota, at the time their petition was filed. During all
relevant years, Dennis Fultz (Mr. Fultz) was a farmer and ran a
farm operation involving grain and livestock. Linda Fultz (Mrs.
Fultz) was also engaged in the farm operations in addition to
running their household.
1. Fultz Farms, Inc.
Fultz Farms, Inc. (Fultz Farms), was incorporated in
December 1990 by Bernard Fultz, Mr. Fultz’s father. During the
1Respondent has conceded an adjustment in “1.A. AG Rent-SE
Income” for 1993, 1994, and 1995, along with the corollary and
computational adjustments associated with that adjustment. In
addition, petitioners presented no argument nor provided any
evidence with regard to adjustments “1.B. Dividends” or “1.F.
Patronage Dividends” for any year and therefore have conceded
those adjustments.
2Unless 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. All dollar amounts are rounded.
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