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by the written lease, "but to those obligations that existed
within the overall scheme of the farming operations which were to
take place" on their property. Mizell v. Commissioner, T.C.
Memo. 1995-571. (Emphasis supplied.) These include petitioners'
obligations as longstanding participants in the farming business
as well as the "general understanding between * * * [petitioners
and McNamara Farms] with respect to the production of
agricultural products". Id. Viewed in this light, the
arrangement between petitioners and McNamara Farms provided, or
contemplated, that petitioners materially participate in the
production of agricultural commodities on the farmland.
Mr. McNamara was candid as is evident from the following
question during direct examination:
Q. And what do you do for McNamara Farms?
A. I operate the farm. I run the farm from planting to
harvest.
Mr. McNamara claimed he made all the management decisions. Mr.
McNamara asserted that his wife "was a homemaker and ran when she
was needed for, you know, meals or parts." Before incorporation,
Mrs. McNamara did not do the bookkeeping, but otherwise performed
the duties outlined above. Mr. McNamara tried to downplay his
wife's participation. Mrs. McNamara did not appear in Court,
even though petitioners' trial memorandum stated that both
parties would testify. Under these circumstances, we are not
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