Pelaez and Sons, Inc. - Page 7




                                        - 7 -                                         
               Production History--1991 Trees--There were blooms on the               
          1991 trees during early 1993, fruit was visible during the spring           
          1993, and the corporation sold the fruit from the harvest                   
          beginning in October 1993.  Fruit from the 1991 trees won an                
          award, based on size and quality, in a 1993 county fair.                    
               The corporation, for the taxable periods 1991 through 1994,            
          harvested and sold boxes of fruit as follows:                               
                                             Tangerines/                              
          Taxable year ended  Oranges     Grapefruit      tangelos                    
          Sept. 30, 1991      -0-                 80        -0-                       
          Sept. 30, 1992      4,465          967            118                       
          Sept. 30, 1993      28,906         30,439         3,469                     
          Sept. 30, 1994      36,242         36,836         9,413                     
          Production information for 1989 trees and 1991 trees was not                
          segregated.                                                                 
               During October 1993, a group described as the “Florida                 
          Citrus Liaison Team” was formed, and it consisted of five citrus            
          industry representatives, two tax practitioners, and six                    
          representatives from the Internal Revenue Service (IRS).  The               
          IRS’ Specialization Program coordinator (for the citrus industry)           
          was a participant in the liaison group.  The group sought                   
          guidance from the Office of Chief Counsel of the IRS with respect           
          to issues concerning section 263A.  There was a belief within the           
          liaison group that IRS examiners were not uniformly applying the            
          section 263A provisions.                                                    








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011