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found that during 1995 the wages that JJ & P Farms, Inc., paid to
petitioners for petitioners’ farm-related activities in the
production of agricultural commodities were calculated without
regard to the activities that petitioners performed with respect
to processing hogs through petitioners’ 800-head capacity hog
barn.
We have rejected the two reasons that petitioners advance in
support of their position that there was no 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 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 that barn. On the record
before us, we find no other reason that would support petition-
ers’ position that there was no such nexus.
Pursuant to the modified oral rental arrangement, the rent
that JJ & P Farms, Inc., was required to, and did, pay to peti-
tioners during 1995 with respect to petitioners’ 800-head capac-
ity hog barn depended on the number of hogs that petitioners
processed through that barn. During 1995, as a condition to JJ &
P Farms, Inc.’s, being obligated pursuant to that modified rental
arrangement to pay rent to petitioners for that barn, petitioners
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