Rollin Morehouse v. Commissioner of IRS

BEAM, Circuit Judge.

The Tax Court determined that payments received by Rollin and Maureen Morehouse under the United States Department of Agriculture’s Conservation Reserve Program (CRP), 16 U.S.C. §§ 3801, 3831-35, constituted income from self-employment for purposes of 26 U.S.C. § 1401. We reverse.

I. BACKGROUND

Morehouse1 holds a bachelor’s degree in business from the University of Minnesota. *618Following graduation he worked as a regional sales manager and as an associate publisher. From 1987 through 2003, Morehouse provided marketing and fund-raising services for the University of Texas at…