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for purposes of the self-employment tax.
Petitioners originally purchased stock and units of equity
participation in MCP and executed their first UMAs to enhance
their ability to profit from the corn they grew on their farm.
Their membership in MCP enabled them to arrange for cost-
effective processing of the corn they grew and for the marketing
and sale of their corn and corn products through MCP. The
relationship apparently was so beneficial that, over the years,
petitioners continued to buy additional units of equity
participation, thereby increasing the amount of corn they would
be required to produce under the UMAs but also increasing the
amount of money they would be entitled to receive under the UMAs.
Although petitioners retired from daily farming in 1987 and
turned over their farm operation to the sons, petitioners
nevertheless continued to maintain their membership in MCP from
1987 through at least 1995. As active members of MCP during 1994
and 1995, petitioners, either directly or through the sons as
their agents,13 regularly and continuously (1) maintained their
status as producers under the UMAs, (2) made decisions regarding
how to satisfy their production and delivery obligations to MCP
under the UMAs, (3) acquired option pool corn which they used to
satisfy their production and delivery obligations to MCP several
13Petitioners testified that the sons acted on their behalf
and do not dispute that the sons operated as their agents in
delivering and selling corn and other produce for their benefit.
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