Curtis and Mary Ettesvold - Page 2

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                Neither petitioners’ motion nor respondent’s response                
            thereto requests an evidentiary hearing, and the Court                    
            concludes that such a hearing is unnecessary for the                      
            disposition of petitioners’ motion.  See Rule 232(a)(2),                  
            Tax Court Rules of Practice and Procedure.  We will decide                
            petitioners’ motion on the basis of the record in this case,              
            including petitioners’ motion, respondent’s response, and                 
            the various exhibits attached thereto.  At the time they                  
            filed their petition, petitioners resided at Morris,                      
                 Respondent determined deficiencies in petitioners’                   
            self-employment taxes for 1994 of $5,139 and for 1995 of                  
            $5,048.  Respondent’s determination was based upon the                    
            contention that certain payments received from petitioners’               
            farming corporation constituted “net earnings from self-                  
            employment” pursuant to section 1402(a)(1) of the Internal                
            Revenue Code.  Hereinafter, all section references are to                 
            that Code unless stated otherwise.                                        
                 As a general rule, section 1402(a)(1) defines “net                   
            earnings from self-employment” to exclude rentals of farm                 
            land and personal property, but it sets forth an exception                
            to the general rule if the rental income is derived under an              

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