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OPINION
SWIFT, Judge: Respondent determined deficiencies in
petitioners’ 2001 Federal income taxes and penalties, as follows:
Penalty
Petitioners Deficiency Sec. 6662(b)(1)
Jon W. and Kristi Nelson $23,707 $4,741
Steven P. and Jaime Nelson 31,197 6,239
Wayne E. and Joann Nelson 23,181 4,636
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the relevant years, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
The issue for decision is whether two farming partnerships
and the partners thereof may, under section 451(d), defer
reporting as income until 2002 Federal crop insurance proceeds
the partnerships received in 2001 relating to their destroyed
sugar beet crops.
Background
The facts of this case were submitted fully stipulated under
Rule 122 and are so found.
At the time the petitions were filed, petitioners resided in
Minnesota.
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Last modified: March 27, 2008