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(CFO), respectively, and were to perform in such respective
capacities the same farm-related activities in the production of
agricultural commodities that they had been performing since they
began farming in the early 1960's (petitioners’ farm-related
activities).4 Pursuant to that arrangement, at all relevant
times, including during the years at issue, Mr. Johnson,5 as CEO,
and Ms. Johnson,6 as CFO, performed those activities.
At all relevant times before and after petitioners incorpo-
rated their farming operations, the success of those operations
depended upon petitioners’ farm-related activities.
During the years at issue, G.E. Johnson, Inc., did not pay
any wages or other compensation to petitioners in exchange for
petitioners’ farm-related activities in the production of agri-
cultural commodities, except for $1,000 of wages paid to Mr.
Johnson and $44,878 of compensation paid to Mr. Johnson and/or
Ms. Johnson during 1994 and 1995, respectively.
During each of the years at issue, petitioners leased to
G.E. Johnson, Inc., pursuant to an oral arrangement (oral rental
4G.E. Johnson, Inc., did not interview any other individuals
to perform the farm-related activities that it hired petitioners
to perform.
5At all relevant times, Mr. Johnson spent virtually 100
percent of his time working for G.E. Johnson, Inc.
6At all relevant times, Ms. Johnson spent 100 percent of her
time working for G.E. Johnson, Inc.
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