- 2 -
Loss From Farming (petitioners’ 2001 Schedule F), included as
part of their tax return for that year. We hold that they are
not.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted
under Rule 122,1 have been stipulated by the parties and are so
found except as stated below.
Petitioners, who at all relevant times had two children,
resided in Sioux Falls, South Dakota (Sioux Falls), at the time
they filed the petition in this case.
At all relevant times, petitioner Darwin J. Albers (Mr.
Albers) owned and operated a grain farm (farming business) near
Sioux Falls.
On a date not disclosed by the record, Mr. Albers and
petitioner Peggy L. Albers (Ms. Albers) signed a two-page
preprinted form entitled “WRITTEN EMPLOYMENT AGREEMENT” (Ms.
Albers’s employment agreement).2 Ms. Albers’s employment agree-
ment provided in pertinent part:
THIS AGREEMENT, made by and between Peggy Albers (here-
inafter “Employee”), and Darwin Albers (hereinafter
“Employer”):
1All Rule references are to the Tax Court Rules of Practice
and Procedure. All section references are to the Internal
Revenue Code in effect for the year at issue.
2The word “SAMPLE” appeared across the first page of the
employment agreement.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: November 10, 2007