- 6 - 1991 petitioners owned approximately 40,000 laying hens. By 1997 this number had increased to approximately 57,000. Petitioner received CRP payments in the amount of $18,190 in 1992. In the same year petitioner received cost-share payments for establishing ground cover on the CRP land.2 In 1993, he received CRP payments totaling $18,267. In 1992, Mrs. Wuebker began attending college, and, in 1993, she was employed part-time. On Schedule E of the returns for 1992 and 1993, petitioners reported rents received on the CRP land, less mortgage interest and taxes,3 as farm rental income not subject to self-employment taxes. For 1992, petitioners included the cost-share payments received with respect to the CRP land on Schedule F, Profit or Loss From Farming.4 Petitioners paid self-employment taxes with respect to petitioner’s reported net profit from farming. In the notice of deficiency, respondent determined that the amounts received by petitioner under the CRP contract, less the 2 On the record, the amount of such payments is not clear. 3 In 1992, petitioners did not claim a deduction for taxes on Schedule E. 4 The parties stipulated that petitioners reported the CRP contract payments and related expenses on Schedule E for the taxable years 1992 and 1993. To the extent that this stipulation is contrary to the facts revealed on the record, we are not bound by it. Cal-Maine Foods, Inc. v. Commissioner, 93 T.C. 181, 195 (1989).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011