Gerald E. Johnson and Dorothy Johnson - Page 5

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          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.                                                               





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