- 10 - from MCP. The Fultz Farms payments were made after the issuance of the MCP value-added checks to petitioners. Netted across the years, respondent’s adjustments appear to be lower than the amounts petitioners received from MCP. Petitioners do not contest respondent’s adjustment calculations. We accept these adjustments as a partial concession by respondent. However, our holding is based upon the original payments from MCP to petitioners, not petitioners’ relationship with Fultz Farms. Respondent also made an adjustment increasing petitioners’ income tax deduction equal to one-half of the amount of petitioners’ self-employment tax for each of 1993, 1994, and 1995. OPINION This case presents the question whether value-added payments petitioners received from MCP, a Minnesota agricultural cooperative, are subject to self-employment tax under section 1401(a). Payments from MCP have previously been the subject of decisions of this Court and the Court of Appeals for the Eighth Circuit, where an appeal of this case would lie. In Bot v. Commissioner, 118 T.C. 138 (2002), affd. 353 F.3d 595 (8th Cir. 2003), this Court held and the Court of Appeals affirmed that value-added payments received by members of MCP were subject toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011