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Abstract

The long-awaited appellate decision in Wuebker v. Commissioner was handed down on March 3, 2000 by the Sixth Circuit Court of Appeals. The Sixth Court reversed the Tax Court and held that Conservation Reserve Program (CRP) payments are subject to self-employment tax if the taxpayer is carrying on a trade or business and the CRP land bears a “direct nexus” relationship to the trade or business of farming or ranching.

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