- 30 -
were obligated or compelled to perform petitioners’ farm-related
activities in the production by that company of agricultural
commodities by processing hogs through that barn. If during 1995
petitioners had not performed any of petitioners’ farm-related
activities in the production by JJ & P Farms, Inc., of agricul-
tural commodities with respect to petitioners’ 800-head capacity
hog barn and therefore did not process any hogs through 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, which is the
amount of the 1995 claimed rent for petitioners’ 800-head capac-
ity hog barn.
Based upon our examination of the entire record in this
case, we find that petitioners have failed to establish that
during 1995 there was no nexus between (1) the 1995 claimed rent
for petitioners’ 800-head capacity hog barn that petitioners
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 NextLast modified: May 25, 2011