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benefits are includable in determining the recipient's net
earnings from self-employment.
In our view, Rev. Rul. 60-32, supra, is not persuasive in
these circumstances. The IRS did not address whether the
payments constituted rentals.
The CRP payments received by petitioner during the years in
issue were rentals from real estate and not self-employment
earnings.
We have considered all of the arguments presented by the
parties, and, to the extent not discussed above, they are without
merit or not relevant.
To reflect the foregoing,
Decision will be entered
under Rule 155.
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Last modified: May 25, 2011