The announcement on October 20, 2003, that the Internal Revenue Service was entering a non-acquiescence in the appellate court decision of McNamara v. Commissioner¹ signaled that more cases would be filed in the long line of court decisions since Mizell v. Commissioner.² Two more Tax Court cases³ have confirmed that the Internal Revenue Service is continuing to audit returns involving rental of land (and other property) to a family-owned entity and to assert self-employment tax liability on the rents involved.