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162(a)1 certain amounts in excess of those conceded by respondent
for “Employee benefit programs” that petitioners claimed in
Schedule F, Profit or Loss From Farming (Schedule F), included as
part of petitioners’ tax return for each of those years. We hold
that they are.
FINDINGS OF FACT
All of the facts in this case, which the parties submitted
under Rule 122, have been stipulated by the parties and are so
found except as stated below.
Petitioners resided in Newton, Iowa, at the time they filed
the petition in this case.
At all relevant times, petitioner Ralph E. Frahm (Mr. Frahm)
owned and operated a grain and livestock farm (farming business)
in Newton, Iowa.
During 2000, 2001, and 2002, the years at issue, Mr. Frahm
had one employee in his farming business, viz., his spouse
petitioner Erika Frahm (Ms. Frahm). During those years, Ms.
Frahm performed field jobs, cared for livestock, assisted with
machinery repairs, maintained bookkeeping records, and performed
certain other tasks that were usual and customary to Mr. Frahm’s
farming business. During each of the years 2000, 2001, and 2002,
Mr. Frahm paid Ms. Frahm annual wages of $3,000 for those ser-
1All section references are to the Internal Revenue Code in
effect for the years at issue. All Rule references are to the
Tax Court Rules of Practice and Procedure.
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