- 10 - there shall be material participation by the owner in the production or the management of the production of such agricultural commodities, and there is such material participation by the owner, then the rental income received by the owner pursuant to the arrangement is considered earnings from self-employment. Sec. 1.1402(a)-4(b), Income Tax Regs. Accordingly, we find that the rental income is includable farm rental income that is part of Mrs. Hennen's net earnings from self-employment under section 1402(a)(1) for each of the taxable years at issue. This is the same conclusion we reached in a similar case, decided after this case was heard. Bot v. Commissioner, T.C. Memo. 1999-256. We have considered all of the arguments presented by the parties, and, to the extent not discussed above, they are without merit or not relevant. To reflect the foregoing, Decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011