- 12 - petitioner in the amount of $2,979,5681 and interest due to petitioner as of that date of approximately $227,9902. Between December of 1995 and February of 1996, settlement agreements were entered into between Blackland, Garland Farms, and a number of the tenant farmers regarding repayment of the loans that the tenant farmers owed to Blackland. Under the terms of the above settlement agreements, crop production costs of certain farmers were to be paid by Blackland, and in return the farmers promised to transfer any crop proceeds, crop insurance payments, and Government payments received first to Garland Farms in payment of rent on the farm properties and then to Blackland in repayment of the loans. In February of 1996, a number of the tenant farmers who had past due loans owed to Blackland and who had not yet entered into settlement agreements with Garland Farms and Blackland filed for bankruptcy. For the first time, on Blackland’s March 31, 1996, balance sheet (and thereafter on its balance sheets for April and May 1996) there is reflected a “Note Receivable” from petitioner, 1 $3,545,020 less $565,452 ($724,480 transferred by Blackland to petitioner less $159,028 of purported interest) equals $2,979,568. 2 A “worksheet” of petitioner’s that was stipulated to by the parties reflects unpaid accrued interest for 1993 through 1995 owed to petitioner by Blackland in the amount of $227,990, or $20 less than the $228,010 interest claimed by petitioner as part of the bad debt deduction in issue.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011