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stated as such, the thrust of petitioners' position is that the
word "arrangement" connotes some form of contractual
relationship, the terms and conditions of which must be set forth
in a single contract. Respondent takes the position that the
word "arrangement" should be construed to take into account the
entire understanding between petitioner and his sons (operating
through Mizell Farm) with respect to the farming operations
conducted on the property. According to respondent, the
partnership agreement, which petitioner agrees obligates him to
materially participate in the production of agricultural products
on the property, must be considered along with the leases in
establishing the terms of the arrangement. Respondent further
argues that even if the arrangement is limited to the leases, the
leases provide for the material participation of petitioner as a
partner in Mizell Farm.
Although nowhere defined in the Internal Revenue Code, the
word "arrangement" appears in more than 90 sections. Where a
word used in a statute is not specifically defined, we apply the
language's plain, obvious, and rational meaning. American
Tobacco Co. v. Patterson, 456 U.S. 63, 68 (1982); United States
v. Merriam, 263 U.S. 179, 187-188 (1923). The word "arrangement"
is defined as an agreement. Webster's Third New International
Dictionary 120 (1993). While the concept of an agreement
certainly includes a contractual agreement, it is a broader
concept that would also include other forms of agreements not
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