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The statute, the regulations, and the CRP contract identify
the payments as rental payments or rent. The CRP statute and
regulations repeatedly and consistently refer to the annual
payments as rent or rentals. See 16 U.S.C. secs. 3833(2),
3834(a), (c); 7 C.F.R. secs. 1401.3, 1410.101 (1998). Generally
in construing the meaning of a statute, we give the language its
plain meaning, assuming that Congress uses common words in their
popular meaning and relying on the words as generally understood.
Norfolk S. Corp v. Commissioner, 104 T.C. 13, 36-37, modified 104
T.C. 417 (1995), affd. 104 F.3d 240 (4th Cir. 1998).
The primary purpose of the CRP is to achieve specified
environmental benefits, in particular, reducing soil erosion by
removing land from production. See S. Rept. 101-357, at 199-200
(1990); H. Rept. 99-271(I) at 81 (1985). In determining the
acceptability of bids, the Secretary of Agriculture may consider
the extent to which the enrollment of land would improve the soil
resources, water quality, or wildlife habitat or provide other
environmental benefits. 16 U.S.C. sec. 3834(c)(3). Consistent
with these goals, under the CRP contract petitioner was
prohibited from harvesting the CRP land and was required to
implement a conservation plan. Beyond establishing vegetative
ground cover in the first year of the contract, for which
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