(petitioner inherited farmland in South Dakota and purchased additional South Dakota tracts from family members and enrolled the land in the CRP; petitioner lived in Texas and hired manager to establish cover crop and maintain weed control as required by CRP contract; petitioner reported CRP payments on Schedule E (no self-employment tax); IRS asserted that CRP income should have been reported on Schedule F (subject to self-employment tax); court determined that petitioner in trade or business of participating in the CRP with profit intent; court skipped over material participation requirement and determined existence of trade or business on either petitioner's personal involvement with CRP contract or via paid manager without noting that imputation of agent's activities is blocked when material participation requirement is routed through I.R.C. Sec. 1402; court cited Sixth Circuit decision in Wuebker as controlling even though taxpayer in that case was a farmer and petitioner here was a mere investor that never farmed).
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