Legal Opinion

Jelle v. Commissioner

United States Tax Court

Decided January 31, 2001No. 20059-98Published

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.

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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 remaining loan balance of $ 177,772, and (3) Ps entered into a net recovery buyout recapture agreement to repay to FmHA amounts written off in the event that they…

1Opinion of the Court

DENNIS AND DORINDA J. JELLE, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Jelle v. Commissioner

No. 20059-98

United States Tax Court

116 T.C. 63; 2001 U.S. Tax Ct. LEXIS 6; 116 T.C. No. 6;

January 31, 2001, Filed

Decision will be entered for respondent.

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…

2Cases cited8 opinions

  1. United States v. Kirby Lumber CoSupreme Court of the United States · 1931
  2. Zappo v. CommissionerUnited States Tax Court · 1983
  3. Walker v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1937
  4. Jelle v. CommissionerUnited States Tax Court · 2001
  5. Carolina, C. & O. R. Co. v. CommissionerUnited States Tax Court · 1984

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