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documentary evidence. We therefore conclude that the $3,845
represents compensation earned during the training period.
Section 1401 imposes a tax on self-employment income of
every individual for old age, survivors, and disability
insurance, and for hospital insurance. Sec. 1401(a) and (b);
Schelble v. Commissioner, 130 F.3d 1388, 1391 (10th Cir. 1997),
affg. T.C. Memo. 1996-269. Self-employment income is “the net
earnings from self-employment derived by an individual” during
the taxable year. Sec. 1402(b). The earnings of an insurance
agent who is an independent contractor generally are
self-employment income subject to self-employment tax. Schelble
v. Commissioner, supra; Simpson v. Commissioner, 64 T.C. 974,
983-987 (1975); Erickson v. Commissioner, T.C. Memo. 1992-585,
affd. without published opinion 1 F.3d 1231 (1st Cir. 1993).
Petitioner does not dispute that he was an independent
contractor during his training period with MetLife. Accordingly,
any income petitioner earned during that time is subject to self-
employment tax. Although petitioner did not receive the $3,845
until after he became an employee of MetLife, the income was
derived from self-employment. See sec. 1402(b). Accordingly,
the $6,005 is subject to self-employment tax.
3. Whether Petitioners Are Liable for an Accuracy-Related
Penalty Under Section 6662
Respondent asserted an accuracy-related penalty against
petitioners as to each adjustment in the notice of deficiency.
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