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and his sons, that the rents were received by petitioner in
connection with an arrangement that provided for petitioner's
material participation in the production of agricultural products
on his property. Accordingly, the rental income from the
agricultural leases is included in petitioner's net earnings from
self-employment pursuant to section 1402(a)(1) for each of the
years in issue.
Because of our construction of the word "arrangement" as
used in section 1402(a)(1), we need not consider whether the
leases, in and of themselves, provided for petitioner's material
participation in the production of agricultural products on the
property.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: May 25, 2011