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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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