- 2 - The issues for decision are: (1) Whether petitioners are entitled to exclude all of their income from Federal income taxation, and (2) whether petitioners are entitled to deduct payments made into a reserve account. FINDINGS OF FACT The parties submitted this case fully stipulated. The stipulation of facts, the supplemental stipulation of facts, and the attached exhibits are incorporated herein by this reference. Petitioners resided in Cherokee, North Carolina, at the time they filed their petition. Petitioner Frela D. Beck is an enrolled member of the Eastern Band of the Cherokee Indians. During 1992 and 1993, petitioners owned and operated apartment buildings located on a Cherokee Indian Reservation in North Carolina. The legal title to the land on which the apartment buildings sit is vested in the United States of America and held in trust for the Eastern Band of Cherokee Indians. Petitioners entered into a loan agreement in the amount of $376,000 with the Farmers Home Administration (FmHA) of the U.S. Department of Agriculture in order to construct the apartment buildings. The loan agreement required petitioners to deposit a total of 10 percent of the loan amount into a reserve account. 1(...continued) Procedure.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011