Earl M. Hasbrouck and Donna M. Hasbrouck - Page 5

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          the conservation plan; and (3) provide technical assistance to              
          assist the owner or operator in carrying out the contract.                  
               On December 31, 1987, petitioners signed a Form CRP-1,                 
          Conservation Reserve Program Contract (the contract) to continue            
          the enrollment of the 62 acres2 in the CRP.  The contract                   
          provided for an annual rental rate of $43 per acre and was to be            
          effective until 1996.  A representative of the CCC signed the               
          contract on February 3, 1988.                                               
               An appendix to the contract lists the eligibility                      
          requirements for participation in the CRP.  In pertinent part,              
          the appendix provides:                                                      
               2    ELIGIBILITY REQUIREMENTS                                          
                    A    In order for any person to be                                
                         eligible for payments under this                             
                         contract, such person must be an                             
                         owner or operator of eligible                                
                         cropland and --                                              
                         *    *    *    *    *    *    *                              
                         (2) if an owner of eligible                                  
                              cropland, must have owned such                          
                              cropland for not less than 3                            
                              years prior to the close of                             
                              the applicable period for                               
                              entering in Contracts with                              
                              CCC, unless:                                            
                              *    *    *    *    *    *    *                         
                              (c) it is determined that the                           
                                   new owner of such                                  

               2 There is evidence in the record that at some later time,             
          65.1 acres, rather than 62 acres, were placed in the CRP.                   




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