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had any net earnings from self-employment as that term is used in
section 1402(a)(1).
In light of all the facts and circumstances, we must decide
whether Mrs. Bot received rental income from Mr. Bot pursuant to
an "arrangement" between the parties to produce agricultural
commodities on the farm within the meaning of section
1402(a)(1)(A).
In Mizell v. Commissioner, T.C. Memo. 1995-571, this Court
explained that:
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 necessarily
arising from strict contractual relationships. Consistent
with its dictionary definition, in most of the instances
where it is used in the Internal Revenue Code, the word
"arrangement" refers to some general relationship or overall
understanding between or among parties in connection with a
specific activity or situation. Generally, it is not
limited only to contractual relationships, or used in a way
that suggests that its terms and conditions must be included
in a single agreement, contractual or otherwise. Congress
obviously recognized a distinction between a contract and
the broader concept of an "arrangement", as is evident from
those sections of the Internal Revenue Code that make
reference to both. * * *
The parties stipulated that Mr. Bot used the farmland to
produce agricultural commodities such as livestock and crops.
With respect to whether under the arrangement Mrs. Bot was to
materially participate in the farming operations, we look not
only to the obligations imposed upon Mrs. Bot by the oral lease,
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