Frederick J. and Ruth Wuebker - Page 15

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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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