Michael and Nancy McNamara - Page 11




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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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