- 3 - FINDINGS OF FACT Some facts are stipulated and are so found. The stipulation of facts, with accompanying exhibits, is incorporated herein by this reference. At the time they filed the petition, petitioners resided in Onslow, Iowa. For many years prior to the years at issue, petitioners engaged in farming operations in Jones County, Iowa. In 1993, petitioners incorporated their farming operations by transferring their farming equipment, grain, and livestock to two subchapter C corporations: Welter Seed & Honey Co. and Land of Milk & Honey Farms, Inc. (the corporations). Petitioners retained ownership of their farmland and leased it to the corporations for use in the corporations’ farming operations. Petitioners also received a modest salary from the corporations. During the years at issue, each of the corporations maintained its own books and records, had its own bank account, and filed Federal income tax returns. One of the corporations, Land of Milk & Honey Farms, Inc., is listed as the “producer” and the “operator” on Government forms relating to Federal agricultural subsidy programs for each of those years. Prior to the incorporation of petitioners’ farming operations, petitioner Herman Welter (Mr. Welter) engaged in commodities trading activities through several brokerage accounts. Mr. Welter continued to engage in such activitiesPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011