Warfield v. Commissioner
United States Tax Court
Capital gains from sale of farmland development rights to the Maryland Agricultural Land Preservation Foundation are not exempted from the alternative minimum tax imposed by sec. 55, I.R.C. 1954, notwithstanding the Farmland Protection Policy set forth in 7 U.S.C. sec. 4201.
1Opinion of the Court
OPINION
Cohen, Judge:
Respondent determined a deficiency of $10,151 in petitioners’ Federal income taxes for 1981. Respondent also determined an addition to tax for negligence under section 6653(a)1 in the amount of $507.55, but he has now conceded that addition to tax.
The issue to be determined is whether the Farmland Protection Policy set forth in 7 U.S.C. sec. 4201 precludes application of the alternative minimum tax of section 55 to capital gains derived from transfer of farmland development rights to the Maryland Agricultural Land Preservation Foundation.
All of the material facts have been…
2Cases cited13 opinions
- Bulova Watch Co. v. United StatesSupreme Court of the United States · 1961
- Huntsberry v. CommissionerUnited States Tax Court · 1984
- United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
- Estate of Ralph D. Cowser, Deceased, Patricia Ann Tucker v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1984
- Metzger Trust v. CommissionerUnited States Tax Court · 1981
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