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RUTKOSKE v. COMMISSIONER

Docket Nos. 16300-14, 16301-14.

149 T.C. 133 (2017)

149 T.C. No. 6

MARK A. RUTKOSKE, SR., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. FELIX RUTKOSKE, JR., AND KAREN E. RUTKOSKE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed August 7, 2017.

Attorney(s) appearing for the Case

Jay S. Block, for petitioners.

David A. Indek and Nancy M. Gilmore, for respondent.

OPINION

These consolidated cases are before the Court on the parties' cross-motions for partial summary judgment. The issue raised in each party's motion is whether petitioners Mark and Felix Rutkoske were "qualified farmers" at the time they, through Browning Creek, LLC (Browning Creek), a limited liability company of which...

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