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owner pursuant to the arrangement is considered earnings from
self-employment. Id.
In determining whether compensation is includible in
self-employment income under sections 1401-1403 such provisions
are to be broadly construed so as to favor coverage for Social
Security purposes. Braddock v. Commissioner, 95 T.C. 639, 644
(1990). The rental exclusion in section 1402(a)(1) is to be
strictly construed to prevent this exclusion from interfering
with the congressional purpose of effectuating maximum coverage
under the Social Security umbrella. Johnson v. Commissioner, 60
T.C. 829, 832 (1973); Gill v. Commissioner, T.C. Memo. 1995-328.
Petitioners contend that the written lease agreement does
not require material participation by petitioners in the farming
operations. Petitioners further contend that the rental income
that petitioners received from McNamara Farms was cash rent from
real estate, and therefore should be excluded in determining
whether petitioners had any net earnings from self-employment as
that term is used in section 1402(a)(1).
This Court has held that cash rental payments were
includible in self-employment income in Gill v. Commissioner,
supra. This is the same conclusion this Court reached in two
similar cases, decided after this case was heard. Bot v.
Commissioner, T.C. Memo. 1999-256, and Hennen v. Commissioner,
T.C. Memo. 1999-306. In Gill, this Court further held that
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