Jelle v. Commissioner
United States Tax Court
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
- United States v. Kirby Lumber CoSupreme Court of the United States · 1931
- Zappo v. CommissionerUnited States Tax Court · 1983
- Walker v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1937
- Jelle v. CommissionerUnited States Tax Court · 2001
- Carolina, C. & O. R. Co. v. CommissionerUnited States Tax Court · 1984
3 more not listed; retrieve them via the Exa API.