- 4 -
parties owned the remaining 513 acres.4
After the formation of JJ & P Farms, Inc., that company
hired Mr. Solvie and Ms. Solvie pursuant to an oral arrangement
(oral employment arrangement)5 under which Mr. Solvie was to
serve as its chief executive officer (CEO), its chief financial
officer (CFO), and a member of its board and Ms. Solvie was to
serve as a member of its board. Under that arrangement, Mr.
Solvie and Ms. Solvie were to perform in their respective capaci-
ties the same farm-related activities in the production of
agricultural commodities that they had been performing prior to
1991 (petitioners’ farm-related activities). Pursuant to the
oral employment arrangement, at all relevant times, including
during 1993, 1994, and 1995, Mr. Solvie,6 as CEO, CFO, and a
board member, and Ms. Solvie,7 as a board member, performed those
activities. After petitioners incorporated JJ & P, Farms, Inc.,
in 1991 and before petitioners built an 800-head capacity hog
barn in 1995 (discussed below), the farming operation had the
capacity to process 1,000 head of hogs.
4See supra note 3.
5During 1993, 1994, and 1995, petitioners had no written
employment agreement with JJ & P Farms, Inc.
6At all relevant times, Mr. Solvie spent 100 percent of his
time working for JJ & P Farms, Inc.
7At all relevant times, Ms. Solvie spent virtually 100
percent of her time working for JJ & P Farms, Inc.
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