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business was destroyed by fire. The Court found that these
"business interruption proceeds" did not constitute self-
employment income because the taxpayers' failure (inability) to
operate the grocery store business after the fire was what gave
rise to the payment of the proceeds: that event caused the
complete cessation of business activity. The Court thus deemed
that the insurance proceeds did not come from self-employment.
The situation presented in Newberry is not present in the
instant case. Petitioner Connie Ray was a farmer and rancher and
had apparently been so for some years. He owned and operated
farmlands in Texas. As an addition to his holdings, he acquired
the CRP tract and, by agreement with the CCC, he continued in
effect the existing contractual relationship under the CRP
program. Under this program, he was required to tend and nourish
the land, fight diseases, and control soil erosion. What he
could not do is to farm or graze the land. In other words, in
return for nurturing and conserving the CRP acreage, but not
farming or grazing it, he would and did receive a fee from CCC.
Since the CRP acreage was added to his existing farmland, and
since petitioner Connie Ray was already in the business of
farming and ranching, this was a payment to him in connection
with his ongoing trade or business. There is no evidence in the
record that the CCC would have included the acreage here in
question in the CRP program, and would have paid petitioners
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