Frederick J. and Ruth Wuebker - Page 2

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               Paul L. Wright, for petitioners.                                       
               Stephen J. Neubeck, for respondent.                                    

               GERBER, Judge:  This case was heard by Special Trial Judge             
          Stanley J. Goldberg, pursuant to the provisions of section                  
          7443A(b)(3) and Rules 180, 181, and 182.1  The Court agrees with            
          and adopts the opinion of the Special Trial Judge, which is set             
          forth below.                                                                
                         OPINION OF THE SPECIAL TRIAL JUDGE                           
               GOLDBERG, Special Trial Judge:  Respondent determined                  
          deficiencies in petitioners’ Federal income taxes for 1992 and              
          1993 in the respective amounts of $1,685 and $1,640.  The issue             
          for decision is whether petitioners are liable for self-                    
          employment taxes on payments received under the U.S. Department             
          of Agriculture (USDA) Conservation Reserve Program (CRP).                   
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  Petitioners resided in              
          Fort Recovery, Ohio, at the time that they filed their petition.            



          1    Unless otherwise indicated, all section references are to              
          the Internal Revenue Code in effect for the years in issue, and             
          all Rule references are to the Tax Court Rules of Practice and              
          Procedure.                                                                  





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