Nelson v. Commissioner

BYE, Circuit Judge.

Jon W. Nelson, Kristi- Nelson, Steven P. Nelson, Jaime Nelson, Wayne E. Nelson, and Joann Nelson (collectively the Nelsons), appeal the tax court’s 2 decision disallowing their deferment, under Internal Revenue Code (IRC) § 451(d), of crop insurance proceeds to the tax year following their receipt. We affirm.

I

The Nelsons are engaged in two joint farming operations, WJS Nelson, Ltd. LLP, and WJS Nelson Partnership. Among other crops, the Nelsons raise sugar beets. Their normal business practice would be to report sixty-five percent of the income from sugar beet production in…