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money for not farming it, if the land were not appropriate for
farming in the first place.
Supporting our conclusion herein, we consider the provisions
of Rev. Rul. 60-32, 1960-1 C.B. 23. In this ruling, it was
emphasized that there should exist a connection or nexus between
the payments received by the taxpayer and some trade or business
from which they were derived. Rev. Rul 60-32, supra, specifically
concludes that earnings are from self-employment if the taxpayer
derives them from his operation of a farm. While we recognize
that respondent's revenue rulings do not have the force or effect
of law, they can still be helpful in interpreting the statute, as
is Rev. Rul. 60-32, supra, in the present case. See Stubbs,
Overbeck & Association, Inc. v. United States, 445 F.2d 1142 (5th
Cir. 1971). In this case, we are satisfied that the payments
that petitioner Connie Ray received from the CRP program were in
return for caring for the farmland that he owned, as required by
the contract with CCC. Petitioner Connie Ray was an active
farmer/rancher with respect to additional acreage, and the
payments received here had a direct nexus to his trade or
business. We think that these payments were income that was
subject to the self-employment tax of section 1401, and we decide
this issue in favor of respondent.
We have left for consideration the imposition of penalties
under section 6662, which were determined by respondent for each
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