Legal Opinion

Estate of Backemeyer v. Comm'r

United States Tax Court

Decided December 8, 2016No. Docket No. 10596-14Published

Ps were husband and wife. H was a sole proprietor farmer. H purchased certain farm inputs in 2010 intending to use them to cultivate crops the following year. H, a cash-method taxpayer, deducted his expenditures on the inputs under I.R.C. sec. 162 for that same tax year. H died in March 2011 not having used any of the purchased farm inputs. They were subsequently transferred to W, who began her own farming business as sole proprietor upon H's death.

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Ps were husband and wife. H was a sole proprietor farmer. H purchased certain farm inputs in 2010 intending to use them to cultivate crops the following year. H, a cash-method taxpayer, deducted his expenditures on the inputs under I.R.C. sec. 162 for that same tax year. H died in March 2011 not having used any of the purchased farm inputs. They were subsequently transferred to W, who began her own farming business as sole proprietor upon H's death. W used all the farm inputs in 2011 to grow crops that were then sold in 2011 and 2012. W deducted for tax year 2011 an amount equal to the value…

1Opinion of the Court

ESTATE OF STEVE K. BACKEMEYER, DECEASED, JULIE K. BACKEMEYER, PERSONAL REPRESENTATIVE, AND JULIE K. BACKEMEYER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Estate of Backemeyer v. Comm'r

Docket No. 10596-14.

United States Tax Court

2016 U.S. Tax Ct. LEXIS 35; 147 T.C. No. 17;

December 8, 2016, Filed

Decision will be entered under Rule 155.

Ps were husband and wife. H was a sole proprietor farmer. H purchased certain farm inputs in 2010 intending to use them to cultivate crops the following year. H, a cash-method taxpayer, deducted his expenditures on the inputs under I.R.C. sec. 162…

2Cases cited23 opinions

  1. Burnet v. HarmelSupreme Court of the United States · 1932
  2. Bull v. United StatesSupreme Court of the United States · 1935
  3. United States v. Skelly Oil Co.Supreme Court of the United States · 1969
  4. Charles Ilfeld Co. v. HernandezSupreme Court of the United States · 1934
  5. Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983

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