WUEBKER v. COMMISSIONER
United States Tax Court
P executed a contract enrolling his farmland for 10 years in the Conservation Reserve Program. Food Security Act of 1985, Pub. L. 99-198, 99 Stat. 1509-1514, 16 U.S.C. secs. 3831-3836 (1994). P agreed to remove the farmland from production and was required to establish vegetative cover on such land during the first year of the contract.
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P executed a contract enrolling his farmland for 10 years in the Conservation Reserve Program. Food Security Act of 1985, Pub. L. 99-198, 99 Stat. 1509-1514, 16 U.S.C. secs. 3831-3836 (1994). P agreed to remove the farmland from production and was required to establish vegetative cover on such land during the first year of the contract. P was required to maintain established conservation practices throughout the term of the contract, and, in return, P received annual rental payments. HELD: Annual payments received by P under the contract were rentals from real estate and therefore not subject…
1Opinion of the Court
FREDRICK J. AND RUTH WUEBKER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
WUEBKER v. COMMISSIONER
Tax Ct. Dkt. No. 11472-96
United States Tax Court
110 T.C. 431; 1998 U.S. Tax Ct. LEXIS 31; 110 T.C. No. 31;
June 23, 1998, Filed
Decision will be entered under Rule 155.
P executed a contract enrolling his farmland for 10 years in the Conservation Reserve Program. Food Security Act of 1985, Pub. L. 99-198, 99 Stat. 1509-1514, 16 U.S.C. secs. 3831-3836 (1994). P agreed to remove the farmland from production and was required to establish vegetative cover on such land during the first year…
2Cases cited10 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- Federal Election Commission v. Larry R. WilliamsCourt of Appeals for the Ninth Circuit · 1996
- George F. Delno v. Anthony J. Celebrezze, Secretary of Health, Education and WelfareCourt of Appeals for the Ninth Circuit · 1965
- Newberry v. CommissionerUnited States Tax Court · 1981
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