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
Gerber, Judge:
This case was heard by Special Trial Judge Stanley J. Goldberg, pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Goldberg, Special Trial Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for 1992 and 1993 in the respective amounts of $1,685 and $1,640. The issue for decision is whether petitioners are liable for self-employment taxes on payments received under the U.S. Department of…
2Cases cited8 opinions
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
- Cal-Maine Foods, Inc. v. CommissionerUnited States Tax Court · 1989
- 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
- Norfolk Southern Corp. v. CommissionerUnited States Tax Court · 1995
3 more not listed; retrieve them via the Exa API.
3Cited by5 opinions
- Morehouse v. CommissionerUnited States Tax Court · 2013
- Frederick J. and Ruth Wuebker v. CommissionerUnited States Tax Court · 1998
- Rollin J. & Maureen B. Morehouse v. CommissionerUnited States Tax Court · 2013
- Taylor Miller v. CommissionerUnited States Tax Court · 2001
- WUEBKER v. COMMISSIONERUnited States Tax Court · 1998