Eric D. Fultz and Sandra A. Fultz - Page 9

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               c.  Petitioners’ Income Tax Returns and Respondent’s                   
               Determinations                                                         
               Petitioners timely filed their 1994 and 1995 Federal income            
          tax returns.  With respect to self-employment tax, petitioners              
          did not complete and attach to either return a Schedule SE,                 
          Computation of Self-Employment Tax.                                         
               Respondent made adjustments to Mr. Fultz’s self-employment             
          income of $9,618 for 1994 and $14,380 for 1995, which reflect the           
          amounts he ultimately received from Fultz Farms per the lease               
          related to the value-added payments, and in each year the                   
          adjustment is less than the actual value-added payments to Mr.              
          Fultz.  We accept this as a partial concession by respondent, but           
          our holding is based upon the original payments from MCP to Mr.             
          Fultz, not petitioners’ relationship with Fultz Farms.                      
          Respondent completed and attached to the notice of deficiency               
          Schedules SE for Mr. Fultz’s self-employment tax for the years at           
          issue.  No self-employment tax was determined for Mrs. Fultz for            
          1994 or 1995.  Respondent also determined that petitioners are              
          entitled to a deduction equal to one-half of the amount of Mr.              
          Fultz’s self-employment tax liability.                                      
                                       OPINION                                        
               This case presents the question whether value-added payments           
          Mr. Fultz 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             





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