Tunji and Christina Mabinuori - Page 10

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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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