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McNamara v. Commissioner, 236 F.3d at 413.
We have found based on the stipulation of the parties that
the 1993 claimed rent, the 1994 claimed rent, and the modified
1995 claimed rent represented fair market rents and are consis-
tent with the rents paid during those years by G.E. Johnson,
Inc., to other third-party landlords. On the record before us,
we further find that petitioners have established that during
each of the years at issue there was no nexus between (1) the
1993 claimed rent, the 1994 claimed rent, and the modified 1995
claimed rent that petitioners received 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.
Pursuant to the oral rental arrangement, during the years at
issue G.E. Johnson, Inc., 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. Moreover, during those years, 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 to pay rent to petitioners
pursuant to the oral rental arrangement.
Based upon our examination of the entire record in this
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