The uncertainty in handling conservation reserve program (CRP) payments existing since 20031 has been partially reduced, in a manner adverse to taxpayers, by the issuance of Notice 2006-108 in early December, 2006.2 The Internal Revenue Service response to the controversy was to – (1) issue Notice 2006-108;3 (2) announce that a revenue ruling is forthcoming; (3) obsolete Rev. Rul. 60-32,4 a key ruling in this area for nearly 50 years; and (4) invite comments on the Notice through March 19, 2007.