§14011

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.

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.