§14011

Farnsworth under his District Manager’s Appointment Agreement (DMAA) with Farmers Insurance Group, and (2) whether petitioners are liable for self-employment tax under section 14011 on the DMAA “contract value” termination payments.

01 10,090 2,018.00 2002 2,577 515.40 The issues for decision are: (1) Whether the income from the Lucky Kirt Irrevocable Trust (Lucky Kirt Trust) should be attributed to petitioners; (2) whether petitioners are liable for self-employment taxes under section 14011 for the taxable years 1999 through 2002; (3) whether petitioners are liable for tax on a capital gain in taxable year 2001; (4) whether petitioners are liable for accuracy-related penalties under section 6662 for the taxable years 1999

The sole issue for decision is whether petitioners are liable for self-employment tax under section 14011 on value-added payments that they received in 1994 and 1995 from an agricultural cooperative of which they were active members.