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case, we find that petitioners have shown that the 1993 claimed
rent, the 1994 claimed rent, and the modified 1995 claimed rent
were not derived under an arrangement within the meaning of
section 1402(a)(1)(A) and section 1.1402(a)-4(b)(2), Income Tax
Regs., between petitioners and G.E. Johnson, Inc., which provided
or contemplated that G.E. Johnson, Inc., was to produce agricul-
tural commodities on petitioners’ land and that petitioners were
to participate materially in the production of such commodities.
On that record, we hold that the 1993 claimed rent, the 1994
claimed rent, and the modified 1995 claimed rent, reduced by the
deductions attributable to such respective rents, are not subject
to self-employment tax because they do not constitute includible
farm rental income and therefore are not net earnings from self-
employment under section 1402(a)(1).
We have considered all of the contentions and arguments of
the parties that are not discussed herein, and we find them to be
without merit, irrelevant, and/or moot.
To reflect the foregoing and the concession of petitioners,
Decision will be entered
under Rule 155.
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