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"but to those obligations that existed within the overall scheme
of the farming operations which were to take place" on Mrs. Bot's
property. Mizell v. Commissioner, T.C. Memo. 1995-571.
(Emphasis supplied.) These include Mrs. Bot's obligations as a
longstanding participant in the farming business as well as the
"general understanding between * * * [Mr. Bot and Mrs. Bot] with
respect to the production of agricultural products". Id. Viewed
in this light, the arrangement between Mr. and Mrs. Bot provided,
or contemplated, that Mrs. Bot materially participate in the
production of agricultural commodities on the farmland.
Mr. Bot claimed he made all the management decisions and,
despite 38 years of history to the contrary, asserted that he
could operate his farm without help from his wife. Under these
circumstances, we are not required to accept the self-serving
testimony of Mr. Bot as gospel. Tokarski v. Commissioner, 87
T.C. 74, 77 (1986). Although petitioners contend that the
purported oral lease agreement did not require Mrs. Bot to
materially participate in the farming operations, the record
supports a finding that Mrs. Bot played a material role in the
production of agricultural commodities under an arrangement with
her husband.
For about 38 years through the taxable years at issue, Mrs.
Bot performed general farming services on the farm on a regular
and intermittent basis, as we detailed in the findings of fact.
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