3 In the years in question, petitioner Connie Ray was engaged in the active trade or business of farming and/or cattle grazing. In addition to the land that he already owned and used for these purposes, petitioners purchased an additional 1,022 acres of land in the years 1987 and 1989. This land, known hereafter as the CRP land, had been placed under contract by the prior owner with the Commodity Credit Corp. (CCC) in the Federal Conservation Reserve Program (CRP) for a 10-year period. Upon acquisition of this tract, petitioner executed an agreement with the CCC to continue the contract that existed with respect to these tracts of land. The CRP contract required petitioner to maintain vegetative ground cover, to undertake conservation practices to reduce soil erosion, and to carry on other activities to sustain the productive capacity of the land. The contract also provided the following: (1) Petitioners were not permitted to graze, harvest, and/or use the land for any other commercial reasons; and (2) the CCC was required to pay petitioners an annual fee per acre. In 1990, apparently in accordance with the contract with CCC, petitioner did not farm the property, but he did apply herbicide and shredded natural grasses to the CRP tract. For 1989, 1991, and 1992, petitioners reported income from CRP (CCC) on Schedule F of their tax returns as self-employment income. However, for the year 1990, petitioners reported such income from CRP as farm rental income not subject to self-employment tax.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011