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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 includible farm
rental income that is part of petitioners' net earnings from
self-employment under section 1402(a)(1) for each of the taxable
years at issue.
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