Jere J. and Paulette M. Solvie - Page 30

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          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                






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