- 5 - arrangement) farmland7 and certain personal property that they owned (petitioners’ farmland and personal property) located in Renville, Minnesota.8 Pursuant to that arrangement, at all relevant times, including during the years at issue, that company paid rent to petitioners for the lease of petitioners’ farmland and personal property, irrespective of whether or not that company had a good farming year or had income. During the years at issue, petitioners did not believe that they were, and they were not, obligated or compelled to perform petitioners’ farm- related activities in the production by G.E. Johnson, Inc., of agricultural commodities as a condition to that company’s being obligated pursuant to the oral rental arrangement to pay rent to petitioners.9 Petitioners jointly filed Form 1040, U.S. Individual Income Tax Return, for each of their taxable years 1993 (petitioners’ 1993 return), 1994 (petitioners’ 1994 return), and 1995 (peti- tioners’ 1995 return). In petitioners’ 1993 return, petitioners 7G.E. Johnson, Inc., also leased certain other farmland from third-party landlords pursuant to oral rental arrangements with those third-party landlords. 8During the years at issue, petitioners had no written rental agreement with G.E. Johnson, Inc. 9Even if during the years at issue petitioners became sick or incapacitated or otherwise were unable to perform for G.E. Johnson, Inc., petitioners’ farm-related activities in the production of agricultural commodities, that company was nonethe- less obligated pursuant to the oral rental arrangement to pay rent to them.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011