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BOT v. C.I.R.

No. 02-2956.

353 F.3d 595 (2003)

Richard J. BOT; Phyllis Bot, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: December 22, 2003.

Attorney(s) appearing for the Case

was Mark L. Astling, argued, Minneapolis, MN (Kathryn J. Sedo, on the brief), for appellant.

Michael J. Haungs, Tax Division, argued, DOJ, Washington DC (Bruce R. Ellisen, on the brief), for appellee.

Before MORRIS SHEPPARD ARNOLD and HANSEN, Circuit Judges, and READE, District Judge.

HANSEN, Circuit Judge.

Richard J. Bot and Phyllis Bot appeal from the tax court's2 decision upholding the Internal Revenue Service's assessment of self-employment tax on the value-added payments the Bots received from the Minnesota Corn Processors Cooperative Association ("MCP") in 1994 and 1995. The Bots argue that the tax court erred in finding that they earned the value-added payments from the carrying on of a trade or business. We...

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