In an opinion issued October 10, 2014, the 8th Circuit Court of Appeals in the case of Morehouse v. Comr. overturned the decision of the U.S. Tax Court on the issue of whether Conservation Reserve Program (CRP) payments to non-farmers are subject to self-employment tax. The Tax Court had determined that Mr. Morehouse was “‘engaged in the business of participating in the CRP․ with the primary intent of making a profit’ and that there was a sufficient nexus between this business and the CRP payments, thus categorizing the payments as net earnings from self-employment.” The Tax Court rejected the argument that were rentals from real estate and therefore not included in net earnings from self-employment.