Lee Mizell and Pearlene Mizell - Page 3

                                                - 3 -                                                 
            agricultural land from third parties.  Petitioner was the owner                           
            or lessee of 731 acres of cultivated acreage in Lincoln County                            
            (the property) during the years in issue.  Prior to the years in                          
            issue, petitioner farmed the property as a sole proprietor                                
            producing cotton, rice, and soybeans, and included the income                             
            from his farming activities in the computation of his net                                 
            earnings from self-employment.                                                            
                  In 1986, petitioner formed a partnership (Mizell Farm) with                         
            his three sons.  The purpose of Mizell Farm was to conduct                                
            farming operations.  Petitioner held a 25-percent ownership                               
            interest in the partnership.  The partnership agreement provided                          
            that each of the partners would have an equal voice in the                                
            management and conduct of the partnership business, and required                          
            that each partner devote his full time and attention to the                               
            business.  In accordance with the partnership agreement,                                  
            petitioner made management decisions, acquired operating capital,                         
            and contributed physical labor to the farming operation during                            
            the years 1988, 1989, and 1990.  Petitioner included his                                  
            distributive share of the partnership's income in his income on                           
            his Federal income tax returns for each of the years in issue and                         
            treated such income as net earnings from self-employment.                                 
                  On January 1, 1988, petitioner entered into a series of                             
            agricultural leases (leases) wherein petitioner leased the 731                            
            acres of property to Mizell Farm in return for a one-quarter crop                         
            share.  During the years in issue, petitioner and his three sons                          

Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011