110 T.C. No. 31
UNITED STATES TAX COURT
FREDRICK J. AND RUTH WUEBKER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11472-96. Filed June 23, 1998.
P executed a contract enrolling his farmland for
10 years in the Conservation Reserve Program. Food
Security Act of 1985, Pub. L. 99-198, 99 Stat. 1509-
1514, current version at 16 U.S.C. secs. 3831-3836
(1994). P agreed to remove the farmland from
production and was required to establish vegetative
cover on such land during the first year of the
contract. P was required to maintain established
conservation practices throughout the term of the
contract, and, in return, P received annual rental
payments.
Held: Annual payments received by P under the
contract were rentals from real estate and therefore
not subject to self-employment tax under secs. 1401 and
1402, I.R.C.
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