Dennis and Dorinda J. Jelle v. Commissioner

116 T.C. No. 6

UNITED STATES TAX COURT DENNIS AND DORINDA J. JELLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20059-98. Filed January 31, 2001. Ps are the owners of agricultural property which, prior to the transactions at issue, was subject to outstanding mortgages held by the Farmers Home Administration (FmHA). After Ps became unable to meet payment obligations under these mortgages, Ps and FmHA negotiated an alternative arrangement. Pursuant thereto, (1) Ps in 1996 paid to FmHA the $92,057 net recovery value of their property, (2) FmHA in that year wrote off the…