Jon W. and Kristi Nelson, et al. - Page 3




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               Petitioners Jon, Steven, and Wayne Nelson are brothers, and            
          petitioners Kristi, Jaime, and Joann Nelson are their respective            
          wives.                                                                      
               Petitioners herein are partners in two related family                  
          partnerships that are engaged in the business of farming--namely,           
          WJS Nelson, Ltd. LLP (WJS-LLP) and WJS Nelson Partnership (WJS-             
          Partnership).                                                               
               Jon, Steven, and Wayne are equal one-third partners in WJS-            
          LLP, and Jon, Steven, Wayne, and their respective spouses are               
          equal one-sixth partners in WJS-Partnership.                                
               WJS-LLP raises only sugar beets while WJS-Partnership raises           
          sugar beets and other crops.                                                
               In 2001, the sugar beet crops of WJS-LLP and of WJS-                   
          Partnership were destroyed by excess moisture.  Neither                     
          partnership harvested any sugar beets in 2001, and neither                  
          partnership received any proceeds in 2001 or in later years from            
          the sale of sugar beets the partnerships planted in 2001.                   
               Each partnership’s 2001 sugar beet crop, however, was                  
          insured against loss by Federal crop insurance, and in 2001 WJS-            
          LLP and WJS-Partnership received $80,589 and $121,330,                      
          respectively, a total of $201,919, in Federal crop insurance                
          proceeds relating to their sugar beet crops destroyed in 2001.              
               In 2001, WJS-Partnership also planted and harvested other              
          crops.                                                                      







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