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We must decide1 whether certain amounts (reduced by the
deductions attributable to such amounts) that petitioners re-
ceived during the years at issue and that they characterized as
rent are subject to self-employment tax under section
1402(a)(1).2 We hold that they are not.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time petitioners filed the petition in this case,
they resided in Hector, Minnesota.
In 1962, Gerald E. Johnson (Mr. Johnson) began farming. In
1963, Dorothy Johnson (Ms. Johnson) began farming with Mr.
Johnson. Prior to 1989, petitioners farmed 1,030 acres of land,
537 acres of which they owned. Third parties owned the remaining
493 acres.
From the time Mr. Johnson began farming in 1962, he under-
took everything pertaining to running a crop farm by performing
the following farm-related activities in the production of
agricultural commodities: Purchasing crop inputs; selling,
planting, and harvesting crops; hiring, managing, and firing
1In addition to the issue that we address herein, there are
other determinations in the notice of deficiency (notice) that
are computational in that their resolution flows automatically
from our resolution of that issue.
2All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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