Robert E. and Carloyn S. Holmes - Page 15

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             petitioners through 1990 pursuant to subsequent annual                   
             agreements.  Effective for the 1987 crop year, the Calhoun               
             County ASCS Committee designated 36.3 of petitioners' total              
             165 acres as "cropland".                                                 
                  Petitioners planted crops on 23.6 acres during 1987,                
             including 13.6 acres of corn and 10 acres of soybeans.                   
             Petitioners harvested 518 bushels of corn in 1987 but did                
             not report any gross income from the sale of corn in that                
             year.  Petitioners reported gross income of $459 from the                
             sale of soybeans in 1987.  The record of this case does not              
             set out the number of bushels of soybeans harvested or the               
             price per bushel petitioners received.  Petitioners also                 
             reported gross income of $3,004 from Government subsidy                  
             payments received in 1987.                                               
                  In 1988, petitioners participated in the "0-92                      
             program".  The ASCS pays a landowner who participates in                 
             this program a specified amount of money per acre per year               
             in exchange for the landowner's agreement to refrain from                
             planting crops on anywhere from zero to 92 percent of his                
             or her total eligible acreage.  The record does not                      
             disclose the amount of money petitioners received under the              
             0-92 program during 1988.  However, petitioners reported                 








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