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to, and did, participate materially in the production by G.E.
Johnson, Inc., of agricultural commodities by performing peti-
tioners’ farm-related activities; and (2) an oral rental arrange-
ment under which petitioners leased to G.E. Johnson, Inc.,
petitioners’ farmland and personal property. There were two
identical types of arrangements involved in McNamara II. The
issue presented here is whether the claimed rents at issue,
reduced by the deductions attributable to such respective rents,
are subject to self-employment tax because they constitute
includible farm rental income under section 1402(a)(1). That was
the identical issue presented in McNamara II. We conclude that
McNamara II is squarely in point. Moreover, the court to which
an appeal in this case would normally lie is the Court of Appeals
for the Eighth Circuit. We shall follow McNamara II. Golsen v.
Commissioner, supra.
As required by McNamara II, we must determine whether there
was a nexus between (1) the 1993 claimed rent, the 1994 claimed
rent, and the modified 1995 claimed rent that petitioners re-
ceived pursuant to the oral rental arrangement and (2) the oral
employment arrangement under which petitioners were to, and did,
participate materially in the production by G.E. Johnson, Inc.,
of agricultural commodities.13 In making that determination, we
13We note that in McNamara I there is no indication that the
parties advanced, and the Court did not address, any argument
(continued...)
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