Can part of the Commissions received by an Insurance Agent be considered passive...

[Melinda D]

...income not subject to SE tax? I am curious to know if an Insurance Agent, who receives 1099misc Box 7 Income from the company to which they broker for, is all subject to self-employment tax. Certainly a portion of the income received would be for new business and active participation, but the rest of the income would be from residuals for policies written in years past that don't require much if any effort on the part of the agent. Is there a revenue ruling or other precedence set in allowing a portion of the income to be passive and therefore not subject to Self-Employment taxes?