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NELSON v. C.I.R.

Nos. 08-2912, 08-2916, 08-2918.

568 F.3d 662 (2009)

Jon W. NELSON; Kristi Nelson; Steven P. Nelson; Jaime Nelson; Wayne E. Nelson; Joann Nelson, Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, Eighth Circuit.

Filed: June 10, 2009.

Attorney(s) appearing for the Case

Jon J. Jensen, argued, Grand Forks, ND, for appellant.

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

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

BYE, Circuit Judge.

Jon W. Nelson, Kristi Nelson, Steven P. Nelson, Jaime Nelson, Wayne E. Nelson, and Joann Nelson (collectively the Nelsons), appeal the tax court's2 decision disallowing their deferment, under Internal Revenue Code (IRC) § 451(d), of crop insurance proceeds to the tax year following their receipt. We affirm.

I

The Nelsons are engaged in two joint farming operations, WJS Nelson, Ltd. LLP, and WJS...

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