In a decision handed down by the Eighth Circuit Court of Appeals on December 29, 2000, additional light was cast on how to avoid self-employment tax on rents for those renting land to an entity in which the lessor is materially participating, taking into account the activities of the taxpayer as lessor and the involvement as partner or employee or in any other status. The problem, which arose with the 1995 Tax Court case of Mizell v. Commissioner, applies only to those producing agricultural or horticultural commodities.