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Hennen I that the income received from the rental of the respec-
tive taxpayer-owners’ farmland in question was derived under an
arrangement between the taxpayer-owners of the farmland and their
taxpayer-spouses, which provided that those spouses were to
produce agricultural commodities on that land and that the
taxpayer-owners were to participate materially in the production
of such commodities. We held in Bot I and Hennen I that the
rents at issue in those cases, reduced by the deductions attrib-
utable to such respective rents, were subject to self-employment
tax because they constituted includible farm rental income under
section 1402(a)(1).
In McNamara I, the taxpayer-owners of the farmland in
question contended that the rental agreement or arrangement
involved in that case did not require their material participa-
tion in the production of the agricultural commodities in ques-
tion. We found that the taxpayer-owners played a material role
in production of such commodities under an agreement or arrange-
ment with their wholly owned corporation. We further found in
McNamara I that the income received from the rental of the
taxpayers’ farmland in question was derived under an arrangement
between the taxpayer-owners and their wholly owned corporation,
which provided that that corporation was to produce agricultural
commodities on that land and that the taxpayer-owners were to
participate materially in the production of such commodities. We
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