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the beet crop to Dean Foods. Cf. Ray v. Commissioner, T.C. Memo.
1996-436.
Petitioners emphasize that petitioner spent less than 100
hours per year working to produce the beets. It is true that the
number of hours that petitioner worked towards producing the
beets represented a small fraction of the total number of hours
that he worked on his farm; however, this does not diminish the
pivotal role that petitioner played in producing the beet crops
in 1991, 1992, and 1993. Petitioner performed all of the farming
procedures necessary to produce at least 200 tons of beets for
each of the years in issue. Additionally, petitioner bore the
expenses of the beet seeds, fertilizer, and herbicide. It is
clear that without petitioner's efforts, there would not have
been a beet crop in any of the years in issue.
Because we think that petitioner was required to and did
materially participate in the production of beets on his farm,
the payments received by petitioners do not qualify as rentals
from real estate that may be excluded from the computation of net
earnings from self-employment. In light of our conclusion, it is
not necessary for us to decide whether the payments received by
petitioners constituted rentals or compensation for services.
To reflect our conclusion herein,
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