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that barn, under the modified oral rental arrangement they would
not have received any rent from that company with respect to that
barn. To the extent that during 1995 petitioners performed such
activities by processing hogs through petitioners’ 800-head
capacity hog barn, they would have received from JJ & P Farms,
Inc., with respect to that barn $21 per head, per rotation of
hogs processed through that barn. During 1995, petitioners
processed approximately three rotations of hogs through petition-
ers’ 800-head capacity hog barn as a result of petitioners’ farm-
related activities, and consequently petitioners received $44,500
from JJ & P Farms, Inc., with respect to that barn.
Petitioners jointly filed Form 1040, U.S. Individual Income
Tax Return, for each of their taxable years 1993 (petitioners’
1993 return), 1994 (petitioners’ 1994 return), and 1995 (peti-
tioners’ 1995 return). In petitioners’ 1993 return, petitioners
reported that Mr. Solvie received $18,423.6215 of wages from JJ &
P Farms, Inc. In that return, petitioners reported that Ms.
Solvie received $80 of “Wages, salaries, tips, etc.” from “MORRIS
PUBLIC SCHOOLS”, $24 of “Wages, salaries, tips, etc.” from “IND.
15The parties stipulated that petitioners reported in peti-
tioners’ 1993 return that Mr. Solvie received $18,432.62 of wages
from JJ & P, Farms, Inc. That stipulation is clearly contrary to
petitioners’ 1993 return. That return shows that petitioners
reported that for 1993 Mr. Solvie received $18,423.62 of wages
from JJ & P Farms, Inc. We shall disregard the parties’ stipula-
tion regarding the amount of wages that petitioners reported in
petitioners’ 1993 return Mr. Solvie received from JJ & P Farms,
Inc. See Cal-Maine Foods, Inc. v. Commissioner, 93 T.C. at 195.
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