I 

110TH CONGRESS 

1ST SESSION H. R. 1882 

To amend the Internal Revenue Code of 1986 to authorize agricultural 

producers to establish and contribute to tax-exempt farm risk management accounts in lieu of obtaining federally subsidized crop insurance 

or noninsured crop assistance, to provide for contributions to such accounts by the Secretary of Agriculture, to specify the situations in 

which amounts may be paid to producers from such accounts, and to 

limit the total amount of such distributions to a producer during a 

taxable year, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

APRIL 17, 2007 

Mr. EVERETT (for himself, Mr. BONNER, Mr. ROGERS of Alabama, Mr. 

CRAMER, and Mr. BACHUS) introduced the following bill; which was referred to the Committee on Ways and Means, and in addition to the 

Committee on Agriculture, for a period to be subsequently determined by 

the Speaker, in each case for consideration of such provisions as fall within the jurisdiction of the committee concerned 

A BILL 

To amend the Internal Revenue Code of 1986 to authorize 

agricultural producers to establish and contribute to taxexempt farm risk management accounts in lieu of obtaining federally subsidized crop insurance or noninsured 

crop assistance, to provide for contributions to such accounts by the Secretary of Agriculture, to specify the 

situations in which amounts may be paid to producers 

from such accounts, and to limit the total amount of 


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such distributions to a producer during a taxable year, 

and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Farm Risk Manage5 ment Act of 2007’’. 

6 SEC. 2. FARM RISK MANAGEMENT ACCOUNTS. 

7 (a) IN GENERAL.—Part VII of subchapter B of chap8 ter 1 of the Internal Revenue Code of 1986 (relating to 

9 additional itemized deductions for individuals) is amended 

10 by redesignating section 224 as section 225 and by insert11 ing after section 223 the following new section: 

12 ‘‘SEC. 224. FARM RISK MANAGEMENT ACCOUNTS. 

13 ‘‘(a) DEDUCTION ALLOWED.—In the case of a quali14 fied farmer, there shall be allowed as a deduction for the 

15 taxable year an amount equal to the aggregate amount 

16 paid in cash during such taxable year by or on behalf of 

17 such individual to a farm risk management account of 

18 such individual. 

19 ‘‘(b) MINIMUM CONTRIBUTION REQUIREMENT.—A 

20 deduction shall not be allowed under subsection (a) for 

21 the taxable year with respect to an individual if, during 

22 such taxable year, the aggregate amount contributed by 

23 such individual to farm risk management accounts of the 

24 individual is not equal to at least 2 percent of the individVerDate Aug 31 2005 03:33 Apr 20, 2007 Jkt 059200 PO 00000 Frm 00002 Fmt 6652 Sfmt 6201 E:\BILLS\H1882.IH H1882

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1 ual’s 3-year average of income derived from farming or 

2 ranching. 

3 ‘‘(c) ACCOUNT BALANCE LIMITATION.—A deduction 

4 shall not be allowed under subsection (a) with respect to 

5 any portion of a contribution to a farm risk management 

6 account of an individual if such contribution would result 

7 in the sum of the balances in all such accounts of such 

8 individual to exceed 150 percent of the individual’s 3-year 

9 average of income derived from farming or ranching. 

10 ‘‘(d) QUALIFIED FARMER.—For purposes of this sec11 tion, the term ‘qualified farmer’ means, with respect to 

12 any taxable year, any individual who, during such year— 

13 ‘‘(1) was engaged in the trade or business of 

14 farming or ranching, 

15 ‘‘(2) has in effect an agreement with the Sec16 retary of Agriculture to accept contributions under 

17 this section in lieu of— 

18 ‘‘(A) receiving, after the expiration of any 

19 transition period applicable to the individual 

20 under subsection (g)(2), any Federal subsidy 

21 toward the premium of any crop insurance pol22 icy, or 

23 ‘‘(B) obtaining noninsured crop assistance 

24 under section 196 of the Agricultural Market 

25 Transition Act (7 U.S.C. 7333), and 


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1 ‘‘(3) does not have any federally subsidized crop 

2 insurance policy, except during transition periods ap3 plicable to the individual under subsection (g)(2). 

4 ‘‘(e) FARM RISK MANAGEMENT ACCOUNT.—For pur5 poses of this section— 

6 ‘‘(1) IN GENERAL.—The term ‘farm risk man7 agement account’ means a trust created or orga8 nized in the United States as a farm risk manage9 ment account exclusively for the purpose of making 

10 qualified distributions, but only if the written gov11 erning instrument creating the trust meets the fol12 lowing requirements: 

13 ‘‘(A) No contribution will be accepted un14 less it is in cash. 

15 ‘‘(B) The trustee is a bank (as defined in 

16 section 408(n)) or another person who dem17 onstrates to the satisfaction of the Secretary 

18 that the manner in which such person will ad19 minister the trust will be consistent with the re20 quirements of this section. 

21 ‘‘(C) The assets of the trust will be in22 vested in securities issued by the United States 

23 Treasury or in such other low-risk interest24 bearing securities as are approved by the Sec25 retary. 


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1 ‘‘(D) The assets of the trust will not be 

2 commingled with other property except in a 

3 common trust fund or common investment 

4 fund. 

5 ‘‘(E) The interest of an individual in the 

6 balance in his account is nonforfeitable. 

7 ‘‘(2) QUALIFIED DISTRIBUTION.—The term 

8 ‘qualified distribution’ means any amount paid from 

9 a farm risk management account to the account ben10 eficiary to the extent that such amount when added 

11 to all other amounts paid from such accounts to 

12 such beneficiary during the taxable year (other than 

13 rollover contributions) does not exceed the excess (if 

14 any) of— 

15 ‘‘(A) 80 percent of such beneficiary’s 3- 

16 year average of income derived from farming or 

17 ranching, over 

18 ‘‘(B) such beneficiary’s gross income de19 rived from farming or ranching for the taxable 

20 year. 

21 ‘‘(3) 3-YEAR AVERAGE OF INCOME DERIVED

22 FROM FARMING OR RANCHING.—The term ‘3-year 

23 average of income derived from farming or ranching’ 

24 means, with respect to any individual— 


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1 ‘‘(A) the sum of the individual’s gross in2 come derived from farming or ranching for the 

3 taxable year and the 2 preceding taxable years, 

4 divided by 

5 ‘‘(B) the number of taxable years taken 

6 into account under clause (i) during which such 

7 individual was engaged in the trade or business 

8 of farming or ranching. 

9 ‘‘(4) ACCOUNT BENEFICIARY.—The term ‘ac10 count beneficiary’ means the individual on whose be11 half the farm risk management account was estab12 lished. 

13 ‘‘(5) SPECIAL RULES.— 

14 ‘‘(A) FEDERAL CONTRIBUTIONS.—For 

15 purposes of this title, any amount paid to a 

16 farm risk management account by the Secretary 

17 of Agriculture under subsection (g) shall be in18 cluded in the account beneficiary’s gross income 

19 in the taxable year for which the amount was 

20 contributed, whether or not a deduction for 

21 such payment is allowable under this section to 

22 the beneficiary. 

23 ‘‘(B) OTHER RULES.—Rules similar to the 

24 following rules shall apply for purposes of this 

25 section: 


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1 ‘‘(i) Section 219(d)(2) (relating to no 

2 deduction for rollovers). 

3 ‘‘(ii) Section 219(f)(3) (relating to 

4 time when contributions deemed made). 

5 ‘‘(iii) Section 408(g) (relating to com6 munity property laws). 

7 ‘‘(iv) Section 408(h) (relating to cus8 todial accounts). 

9 ‘‘(f) TAX TREATMENT OF ACCOUNTS.— 

10 ‘‘(1) IN GENERAL.—A farm risk management 

11 account is exempt from taxation under this subtitle 

12 unless such account has ceased to be a farm risk 

13 management account. Notwithstanding the pre14 ceding sentence, any such account is subject to the 

15 taxes imposed by section 511 (relating to imposition 

16 of tax on unrelated business income of charitable, 

17 etc. organizations). 

18 ‘‘(2) TERMINATION OF ACCOUNTS.—If the ac19 count beneficiary ceases to engage in the trade or 

20 business of farming or ranching, such trade or busi21 ness becomes covered under any crop insurance pol22 icy for which a premium subsidy is paid by the Sec23 retary of Agriculture, or the account beneficiary 

24 seeks noninsured crop assistance under section 196 


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1 of the Agricultural Market Transition Act (7 U.S.C. 

2 7333)— 

3 ‘‘(A) all farm risk management accounts of 

4 such individual shall cease to be such accounts, 

5 and 

6 ‘‘(B) the balance of all such accounts shall 

7 be treated as— 

8 ‘‘(i) distributed to such individual, 

9 and 

10 ‘‘(ii) not paid in a qualified distribu11 tion. 

12 ‘‘(g) FEDERAL CONTRIBUTION TO ACCOUNTS.— 

13 ‘‘(1) CONTRIBUTIONS REQUIRED.—Using 

14 amounts in the insurance fund established under 

15 section 516(c) of the Federal Crop Insurance Act (7 

16 U.S.C. 1516(c)), the Secretary of Agriculture shall 

17 match the contributions made for a taxable year to 

18 farm risk management accounts of an individual 

19 who has entered into the agreement with the Sec20 retary required by subsection (d)(2) in an aggregate 

21 amount equal to 2 percent of the individual’s 3-year 

22 average of income derived from farming or ranching. 

23 ‘‘(2) TRANSITION PERIODS.—Notwithstanding 

24 paragraph (1), during the first 3 taxable years for 

25 which the Secretary of Agriculture makes contribuVerDate Aug 31 2005 03:33 Apr 20, 2007 Jkt 059200 PO 00000 Frm 00008 Fmt 6652 Sfmt 6201 E:\BILLS\H1882.IH H1882

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1 tions under such paragraph to farm risk manage2 ment accounts of an individual and during the first 

3 3 taxable years following any taxable year during 

4 which there occurs a qualified distribution from a 

5 farm risk management account of the individual, the 

6 amount contributed by the Secretary may not ex7 ceed— 

8 ‘‘(A) for the first taxable year, 25 percent 

9 of the amount the Secretary would otherwise 

10 contribute under paragraph (1) for that taxable 

11 year, 

12 ‘‘(B) for the second taxable year, 50 per13 cent of the amount the Secretary would other14 wise contribute under paragraph (1) for that 

15 taxable year, and 

16 ‘‘(C) for the third taxable year, 75 percent 

17 of the amount the Secretary would otherwise 

18 contribute under paragraph (1) for that taxable 

19 year. 

20 ‘‘(3) CROP INSURANCE COVERAGE.—During 

21 any transition period applicable to an individual 

22 under paragraph (1), the individual shall procure, as 

23 a condition of receiving contributions under this sub24 section, at least catastrophic risk protection provided 

25 under section 508(b) of the Federal Crop Insurance 


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1 Act (7 U.S.C. 1508(b)). During this period, the indi2 vidual would be covered with any claim at the same 

3 level of coverage purchased, but subject to the condi4 tion that any claim would first use amounts in the 

5 farm risk management accounts of an individual be6 fore conventional crop insurance would make any 

7 payment, if necessary. 

8 ‘‘(h) TAX TREATMENT OF DISTRIBUTIONS.— 

9 ‘‘(1) IN GENERAL.—Any amount paid or dis10 tributed out of a farm risk management account 

11 (other than a rollover contribution described in para12 graph (4)) shall be included in gross income. 

13 ‘‘(2) ADDITIONAL TAX ON NON-QUALIFIED DIS14 TRIBUTIONS.— 

15 ‘‘(A) IN GENERAL.—The tax imposed by 

16 this chapter on the account beneficiary for any 

17 taxable year in which there is a payment or dis18 tribution from a farm risk management account 

19 of such beneficiary which is not a qualified dis20 tribution shall be increased by 15 percent of the 

21 amount of such payment or distribution which 

22 is not a qualified distribution. 

23 ‘‘(B) EXCEPTION FOR DISABILITY OR

24 DEATH.—Subparagraph (A) shall not apply if 

25 the payment or distribution is made after the 


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1 account beneficiary becomes disabled within the 

2 meaning of section 72(m)(7) or dies. 

3 ‘‘(3) EXCESS CONTRIBUTIONS RETURNED BE4 FORE DUE DATE OF RETURN.— 

5 ‘‘(A) IN GENERAL.—If any excess con6 tribution is contributed for a taxable year to a 

7 farm risk management account of an individual, 

8 paragraph (2) shall not apply to distributions 

9 from the farm risk management accounts of 

10 such individual (to the extent such distributions 

11 do not exceed the aggregate excess contribu12 tions to all such accounts of such individual for 

13 such year) if— 

14 ‘‘(i) such distribution is received by 

15 the individual on or before the last day 

16 prescribed by law (including extensions of 

17 time) for filing such individual’s return for 

18 such taxable year, and 

19 ‘‘(ii) such distribution is accompanied 

20 by the amount of net income attributable 

21 to such excess contribution. 

22 Any net income described in clause (ii) shall be 

23 included in the gross income of the individual 

24 for the taxable year in which it is received. 


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1 ‘‘(B) EXCESS CONTRIBUTION.—For pur2 poses of subparagraph (A), the term ‘excess 

3 contribution’ means any contribution (other 

4 than a rollover contribution) which is not de5 ductible under this section. 

6 ‘‘(4) ROLLOVER CONTRIBUTION.—An amount is 

7 described in this paragraph as a rollover contribu8 tion if it meets the requirements of subparagraphs 

9 (A) and (B). 

10 ‘‘(A) IN GENERAL.—For purposes of this 

11 section, any amount paid or distributed from a 

12 farm risk management account to the account 

13 beneficiary shall be treated as a qualified dis14 tribution to the extent the amount received is 

15 paid into a farm risk management account for 

16 the benefit of such beneficiary not later than 

17 the 60th day after the day on which the bene18 ficiary receives the payment or distribution. 

19 ‘‘(B) LIMITATION.—This paragraph shall 

20 not apply to any amount described in subpara21 graph (A) received by an individual from a 

22 farm risk management account if, at any time 

23 during the 1-year period ending on the day of 

24 such receipt, such individual received any other 

25 amount described in subparagraph (A) from a 


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1 farm risk management account which was not 

2 included in the individual’s gross income be3 cause of the application of this paragraph. 

4 ‘‘(5) TRANSFER OF ACCOUNT INCIDENT TO DI5 VORCE.—The transfer of an individual’s interest in 

6 a farm risk management account to an individual’s 

7 spouse or former spouse under a divorce or separa8 tion instrument described in subparagraph (A) of 

9 section 71(b)(2) shall not be considered a taxable 

10 transfer made by such individual notwithstanding 

11 any other provision of this subtitle, and such interest 

12 shall, after such transfer, be treated as a farm risk 

13 management account with respect to which such 

14 spouse is the account beneficiary. 

15 ‘‘(6) TREATMENT AFTER DEATH OF ACCOUNT

16 BENEFICIARY.— 

17 ‘‘(A) TREATMENT IF DESIGNATED BENE18 FICIARY IS SPOUSE.—If the account bene19 ficiary’s surviving spouse acquires such bene20 ficiary’s interest in a farm risk management ac21 count by reason of being the designated bene22 ficiary of such account at the death of the ac23 count beneficiary, such farm risk management 

24 account shall be treated as if the spouse were 

25 the account beneficiary. 


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1 ‘‘(B) OTHER CASES.— 

2 ‘‘(i) IN GENERAL.—If, by reason of 

3 the death of the account beneficiary, any 

4 person acquires the account beneficiary’s 

5 interest in a farm risk management ac6 count in a case to which subparagraph (A) 

7 does not apply— 

8 ‘‘(I) such account shall cease to 

9 be a farm risk management account 

10 as of the date of death, and 

11 ‘‘(II) an amount equal to the fair 

12 market value of the assets in such ac13 count on such date shall be included 

14 if such person is not the estate of 

15 such beneficiary, in such person’s 

16 gross income for the taxable year 

17 which includes such date, or if such 

18 person is the estate of such bene19 ficiary, in such beneficiary’s gross in20 come for the last taxable year of such 

21 beneficiary. 

22 ‘‘(ii) DEDUCTION FOR ESTATE

23 TAXES.—An appropriate deduction shall be 

24 allowed under section 691(c) to any person 

25 (other than the decedent or the decedent’s 


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1 spouse) with respect to amounts included 

2 in gross income under clause (i) by such 

3 person. 

4 ‘‘(i) REPORTS.—The Secretary may require the trust5 ee of a farm risk management account to make such re6 ports regarding such account to the Secretary and to the 

7 account beneficiary with respect to contributions, distribu8 tions, and such other matters as the Secretary determines 

9 appropriate. The reports required by this subsection shall 

10 be filed at such time and in such manner and furnished 

11 to such individuals at such time and in such manner as 

12 may be required by the Secretary.’’. 

13 (b) DEDUCTION ALLOWED WHETHER OR NOT INDI14 VIDUAL ITEMIZES OTHER DEDUCTIONS.—Subsection (a) 

15 of section 62 of such Code is amended by inserting after 

16 paragraph (20) the following new paragraph: 

17 ‘‘(21) FARM RISK MANAGEMENT ACCOUNTS.— 

18 The deduction allowed by section 224.’’. 

19 (c) TAX ON EXCESS CONTRIBUTIONS.—Section 4973 

20 of such Code (relating to tax on excess contributions to 

21 certain tax-favored accounts and annuities) is amended— 

22 (1) by striking ‘‘or’’ at the end of subsection 

23 (a)(4), by inserting ‘‘or’’ at the end of subsection 

24 (a)(5), and by inserting after subsection (a)(5) the 

25 following new paragraph: 


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1 ‘‘(6) a farm risk management account (within 

2 the meaning of section 224(e)),’’, and 

3 (2) by adding at the end the following new sub4 section: 

5 ‘‘(h) EXCESS CONTRIBUTIONS TO FARM RISK MAN6 AGEMENT ACCOUNTS.—For purposes of this section, in 

7 the case of farm risk management accounts (within the 

8 meaning of section 224(e)), the term ‘excess contribution’ 

9 means the sum of— 

10 ‘‘(1) the aggregate amount contributed for the 

11 taxable year to the accounts (other than rollover 

12 contributions described in section 224(h)(4)) which 

13 is not allowable as a deduction under section 224 for 

14 such year, and 

15 ‘‘(2) the amount determined under this sub16 section for the preceding taxable year, reduced by 

17 the sum of— 

18 ‘‘(A) the distributions out of the accounts 

19 with respect to which additional tax was im20 posed under section 224(h)(2), and 

21 ‘‘(B) the excess (if any) of— 

22 ‘‘(i) the maximum amount allowable 

23 as a deduction under section 224(c) for the 

24 taxable year, over 


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1 ‘‘(ii) the amount contributed to the 

2 accounts for the taxable year. 

3 For purposes of this subsection, any contribution 

4 which is distributed out of the farm risk manage5 ment account in a distribution to which section 

6 224(h)(3) applies shall be treated as an amount not 

7 contributed.’’. 

8 (d) TAX ON PROHIBITED TRANSACTIONS.— 

9 (1) Section 4975(c) of such Code (relating to 

10 tax on prohibited transactions) is amended by add11 ing at the end the following new paragraph: 

12 ‘‘(7) SPECIAL RULE FOR FARM RISK MANAGE13 MENT ACCOUNTS.—An individual for whose benefit a 

14 farm risk management account (within the meaning 

15 of section 224(e)) is established shall be exempt 

16 from the tax imposed by this section with respect to 

17 any transaction concerning such account (which 

18 would otherwise be taxable under this section) if, 

19 with respect to such transaction, the account ceases 

20 to be a farm risk management account by reason of 

21 the application of section 224(f)(2) to such ac22 count.’’. 

23 (2) Section 4975(e)(1) of such Code is amended 

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1 ing after subparagraph (E) the following new sub2 paragraph: 

3 ‘‘(F) a farm risk management account de4 scribed in section 224(e),’’. 

5 (e) FAILURE TO PROVIDE REPORTS ON FARM RISK

6 MANAGEMENT ACCOUNTS.—Section 6693(a)(2) of such 

7 Code (relating to reports) is amended by redesignating 

8 subparagraphs (D) and (E) as subparagraphs (E) and 

9 (F), respectively, and by inserting after subparagraph (C) 

10 the following new subparagraph: 

11 ‘‘(D) section 224(i) (relating to farm risk 

12 management accounts),’’. 

13 (f) CLERICAL AMENDMENT.—The table of sections 

14 for part VII of subchapter B of chapter 1 of such Code 

15 is amended by striking the last item and inserting the fol16 lowing: 

‘‘Sec. 224. Farm risk management accounts. 

‘‘Sec. 225. Cross reference.’’. 

17 (g) CONFORMING AMENDMENTS TO FEDERAL CROP

18 INSURANCE ACT.— 

19 (1) PAYMENT OF PORTION OF PREMIUM BY

20 FEDERAL CROP INSURANCE CORPORATION.—Section 

21 508(e) of the Federal Crop Insurance Act (7 U.S.C. 

22 1508(e)) is amended by adding at the end the fol23 lowing new paragraph: 


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1 ‘‘(6) TRANSITION TO FARM RISK MANAGEMENT

2 ACCOUNTS.—If a producer enters into an agreement 

3 under section 224 of the Internal Revenue Code of 

4 1986 to forgo any Federal subsidy toward the pre5 mium of any crop insurance policy in exchange for 

6 contributions by the Secretary to a farm risk man7 agement account of the producer, then, in connec8 tion with the purchase of any crop insurance policy 

9 during the first 3 taxable years for which the Sec10 retary makes contributions under subsection (g) of 

11 such section to a farm risk management account of 

12 the producer, the amount of the premium to be paid 

13 by the Corporation under this subsection shall be 

14 equal to— 

15 ‘‘(A) for the first taxable year, 75 percent 

16 of the amount of the premium that would oth17 erwise be paid by the Corporation under this 

18 subsection; 

19 ‘‘(B) for the second taxable year, 50 per20 cent of the amount of the premium that would 

21 otherwise be paid by the Corporation under this 

22 subsection; and 

23 ‘‘(C) for the third taxable year, 25 percent 

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1 erwise be paid by the Corporation under this 

2 subsection.’’. 

3 (2) FUNDING SOURCE.—Section 516(b) of such 

4 Act (7 U.S.C. 1516(b)) is amended by adding at the 

5 end the following new paragraph: 

6 ‘‘(3) CONTRIBUTIONS TO FARM RISK MANAGE7 MENT ACCOUNTS.—The Secretary shall use the in8 surance fund established under subsection (c) to 

9 make required contributions to farm risk manage10 ment accounts established under section 224 of the 

11 Internal Revenue Code of 1986.’’. 

12 (h) EFFECTIVE DATE.—The amendments made by 

13 this section shall apply to taxable years ending after the 

14 date of the enactment of this Act. 

Æ 


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