DON'T SAY U.S. FARMERS aren't ingenious. Faced with the Reagan administration's determination to hold subsidy payments to $50,000 a person, they are breaking up farms into smaller units. Nationwide, the Department of Agriculture found that 100,000 wheat farms and 160,000 corn farms have sprung up since 1985, a sign that farmers are splitting up properties to get more than one limit on subsidies.

That, of course, is easier said than done. Writing in Agweek, Randall Mikkelsen points out that you just can't set up a separate corporation and give that entity a $50,000 limit. Farmers setting up new operations face close scrutiny from the government. The Department of Agriculture rejects many proposed changes and may audit approved ones. People caught cheating may lose all their subsidies.But there are ways, among them establishing family-farm corporations or limited partnerships to farm new land, dissolving a corporation holding land, entering sharecropping agreements or joint ventures. And with all such things, there's never an ill wind but blows someone some good. A vast new business has sprung up in counseling farmers about how to do it all legally.

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