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               During 1993, 1994, and 1995, JJ & P Farms, Inc., paid wages            
          to petitioners in exchange for petitioners’ farm-related activi-            
          ties in the production of agricultural commodities.  During 1995,           
          the wages that that company paid to petitioners for such farm-              
          related activities were calculated without regard to such activi-           
          ties that petitioners performed with respect to processing hogs             
          through the 800-head capacity hog barn that petitioners built in            
          1995.                                                                       
               During 1993 and 1994, petitioners leased to JJ & P Farms,              
          Inc., pursuant to an oral arrangement (oral rental arrangement)             
          farmland,8 including existing buildings on that land (petition-             
          ers’ farmland), and certain personal property (petitioners’                 
          personal property) that they owned.9  Pursuant to the oral rental           
          arrangement, during each of the years 1993 and 1994, JJ & P                 
          Farms, Inc., was required to, and did, pay to petitioners rent of           
          $29,400 for petitioners’ farmland, exclusive of existing build-             
          ings on that land, and rent of $21,000 for the buildings on that            
               8JJ & P Farms, Inc., also leased certain other farmland from           
          third-party landlords pursuant to oral rental arrangements with             
          those third-party landlords.                                                
               9During 1993 and 1994, petitioners had no written rental               
          agreement with JJ & P Farms, Inc., with respect to the lease of             
          petitioners’ farmland and petitioners’ personal property.                   
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Last modified: May 25, 2011