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
OPINION
Nims, Judge:
Respondent determined a Federal income tax deficiency for petitioners’ 1996 taxable year in the amount of $46,993. Respondent further determined an accuracy-related penalty of $9,399, pursuant to section 6662(a). The issues for decision are:(1) Whether petitioners are required to recognize income in 1996 from cancellation of indebtedness;(2) whether petitioners must report as income amounts received in the form of Social Security benefits; and(3) whether petitioners are liable for the section 6662(a) accuracy-related penalty on account of a substantial understatement of…
2Cases cited7 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
- Carolina, C. & O. R. Co. v. CommissionerUnited States Tax Court · 1984
- White v. CommissionerUnited States Board of Tax Appeals · 1936
2 more not listed; retrieve them via the Exa API.
3Cited by14 opinions
- Benson v. Comm'rUnited States Tax Court · 2004
- Hahn v. Comm'rUnited States Tax Court · 2007
- Brooks v. Comm'rUnited States Tax Court · 2012
- Bullock v. Comm'rUnited States Tax Court · 2017
- Dennis and Dorinda J. Jelle v. CommissionerUnited States Tax Court · 2001
9 more not listed; retrieve them via the Exa API.