Memorandum Opinion
RAUM, Judge:
The Commissioner determined income tax deficiencies of $628 and $653 for petitioner's taxable years 1989 and 1990, respectively. At issue is whether certain "extended earnings" payments to an independent insurance agent are subject to self-employment taxes, pursuant to sections 1401 and 1402.
Petitioner resided in Milwaukee, Wisconsin, at the time he filed...
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