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establish a permanent cover of grass and/or other
vegetation on the land in lieu of cultivating row crops
such as corn. This is intended to prevent erosion of the
soil. The USDA pays one-half of the expenses incurred in
establishing this permanent cover and provides technical
assistance to the owner or operator through the SCS,
conservation districts, U.S. Forest Service, State forestry
agencies, and other agencies.
On May 5, 1986, petitioner signed a contract placing
14.3 acres of the 40-acre parcel in the CRP at an annual
rental rate of $57 per acre. This agreement was to be
effective until 1996. A representative of the Commodity
Credit Corp. approved the contract on or about August 5,
1986.
In 1987, after discussions with Mr. VandenHeede,
Mr. Robinson, and Mr. Douglas Jackson, petitioners'
accountant, regarding the economic feasibility of farming
the land, and after obtaining information from the local
Agriculture Stabilization and Conservation Service (ASCS),
petitioner hired Mr. Robinson as an independent contractor
to till, plant, and harvest row crops on a portion of the
120-acre parcel. Mr. Robinson continued to work for
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