- 9 - 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 ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011