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any of the trees on his property during any of the years
in issue.
Row Crops and Government Subsidy Programs
Shortly after purchasing the 40-acre parcel,
petitioner spoke with Mr. VandenHeede, who suggested
that petitioner contact the local ASC office about the
possibility of placing a portion of the land in the
Conservation Reserve Program (CRP). The CRP is a program
controlled by the U.S. Department of Agriculture (USDA) on
behalf of the Commodity Credit Corp., the SCS, and the U.S.
Forest Service. Under the CRP, the USDA pays an owner or
operator of eligible crop land an annual rental fee in
exchange for the owner's or operator's agreement to use his
or her land in conformance with the USDA's direction. The
amount of annual rental payments under the CRP are based on
bids submitted by the owners or operators of the land. CRP
contracts are generally effective for terms of 10 or 15
years.
When specific property is accepted into the CRP, the
SCS develops a comprehensive plan for managing the land.
Typically, the SCS requires the owner or operator to
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