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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).
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