Hugh G. and Norma J. King - Page 4

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          the years in issue.  During those years, peanut farmers sold                
          peanuts produced in excess of the peanut quota (nonquota peanuts)           
          for about $300 a ton.                                                       
               Petitioners rented the cropland to Shane Roselius in 1995,             
          to George Roselius in 1996 and 1997, and to Brian Watkins in                
          1998.  Petitioners leased the land to Shane and George Roselius             
          (the Roseliuses) for $40 per acre and 14 cents per pound for the            
          peanut quota.2  Under the lease, the Roseliuses could keep the              
          proceeds from the sale of peanuts they produced in excess of the            
          peanut quota.  Petitioners received lease income of about $30,000           
          in 1995.                                                                    
               Under the lease, the Roseliuses were required to:  (1) Pay             
          rent each year in advance by January 15; (2) plant a cover crop             
          within 20 days after the peanuts were harvested; (3) maintain all           
          ditches and terraces; and (4) fertilize the land.                           
               A storm in 1994 destroyed the roof of petitioners’ house,              
          left a foot of water in it, and flooded parts of the farm.  The             
          Federal Government declared the area in which the farm was                  
          located to be a disaster area.  Petitioners received assistance             
          to repair the land.                                                         
               Mr. King spent an amount of time not specified in the record           
          working on the farm during the years in issue.  He plowed                   


               2  The record does not include lease terms for Brian                   
          Watkins.                                                                    




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