Connie D. Ray and Roma Kay Ray - Page 3

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               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.               






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