United States Eighth Circuit

Tax court judgment is affirmed where the court did not err in disallowing the deferment under Internal Revenue Code sec. 451(d) of crop insurance proceeds to the tax year following their receipt, as the IRS' interpretation of the statute is reasonable and avoids a result that is clearly at odds with the legislative history.

Appellate Information

• Decided 06/10/2009
• Published 06/10/2009

Judges

• BYE, Circuit Judge., Before LOKEN, Chief Judge, BYE, Circuit Judge, and MILLER, District Judge.

Court

• United States Eighth Circuit

Counsel

• For Appellant:
  
• Jon J. Jensen, argued, Grand Forks, ND, for appellant.


• For Appellees:
  
• Andrea R. Tebbets, argued, Regina S. Moriarty, on the brief, Washington, DC, for appellee.