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BOT v. COMMISSIONER

Docket No. 14155-98.

118 T.C. 138 (2002)

118 T.C. No. 8

RICHARD J. BOT AND PHYLLIS BOT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 15, 2002.

Attorney(s) appearing for the Case

Kathryn J. Sedo, for petitioners.

Blaine C. Holiday, for respondent.

MARVEL, Judge:

Respondent determined deficiencies in petitioners' Federal income tax for 1994 and 1995 of $7,239 and $13,716, respectively.

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.

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