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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.
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Last modified: May 25, 2011