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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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