Conservation reserve program payments

In CCA 200325002, the Chief Counsel's Office advised that annual rental payments received by a hypothetical taxpayer for land enrolled in a USDA voluntary conservation reserve program constituted self-employment income to such taxpayer that was subject to Self Employment Contribution Act tax wh...

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Bibliographic Details
Published inTax Management Memorandum Vol. 44; no. 17; p. 350
Format Trade Publication Article
LanguageEnglish
Published Washington Bloomberg BNA 25.08.2003
Subjects
Agricultural commodities
Conservation
Farming
Farms
Income taxes
Real estate
Rentals
Self employment
Taxpayers
United States > US
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Summary:In CCA 200325002, the Chief Counsel's Office advised that annual rental payments received by a hypothetical taxpayer for land enrolled in a USDA voluntary conservation reserve program constituted self-employment income to such taxpayer that was subject to Self Employment Contribution Act tax where the taxpayer was engaged in the trade or business of farming for 6 years prior to enrolling the land in the CRP and had personally fulfilled her CRP contractual obligations. The Chief Counsel's Office asserted that, as long as the taxpayers were actively fulfilling their obligations under their CRP contracts, they would both individually be considered to be engaged in the trade or business of farming.
ISSN:0148-8295
1544-077X