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to that court alone. In the instant case, during 1995 petition-
ers had two arrangements with JJ & P Farms, Inc.: (1) An oral
employment arrangement under which petitioners were to, and did,
participate materially in the production by JJ & P Farms, Inc.,
of agricultural commodities by performing petitioners’ farm-
related activities with respect to, inter alia, processing hogs
through petitioners’ 800-head capacity hog barn; and (2) a
modified oral rental arrangement under which petitioners leased
to JJ & P Farms, Inc., inter alia, that barn. There were two
identical types of arrangements involved in McNamara II. The
issue presented here is whether the 1995 claimed rent at issue,
reduced by the deductions attributable to such rent, is subject
to self-employment tax because it constitutes includible farm
rental income under section 1402(a)(1). That was the identical
issue presented in McNamara II. We conclude that McNamara II is
squarely in point. Moreover, the court to which an appeal in
this case would normally lie is the Court of Appeals for the
Eighth Circuit. We shall follow McNamara II. Golsen v. Commis-
sioner, supra.
As required by McNamara II, we must determine whether there
was a nexus between (1) the 1995 claimed rent for petitioners’
800-head capacity hog barn that petitioners received pursuant to
the modified oral rental arrangement and (2) the oral employment
arrangement under which petitioners were to, and did, participate
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