- 3 - B. Western Timber Farm, Inc. Petitioners organized Western Timber Farm, Inc. (Western), on February 4, 1993. Petitioners alternately served as president of Western during the years in issue. On April 20, 1993, Mrs. Arnold signed a Form 2553, Election by a Small Business Corporation, for Western in which she stated that Western wanted to adopt a tax year ending January 31. Mrs. Arnold stated on the form that the year ending January 31 was Western’s natural business year as provided in Rev. Proc. 87-32, secs. 4.01 and 4.02(a), 1987-2 C.B. 396, 399.3 In a letter to Western dated February 12, 1996, respondent acknowledged receipt of the Form 2553 and stated that the acknowledgment was not an acceptance of the election. In a letter to petitioners dated December 21, 1998, respondent said that Western’s S corporation election was not valid. In a letter to respondent dated July 28, 1999, Mr. Arnold protested respondent’s denial of Western’s S corporation election and argued that Western was entitled to adopt a fiscal year ending January 31. In a letter to Mr. Arnold dated March 19, 2001, respondent stated that respondent had reviewed Western’s Form 1120S, U.S. Income Tax Return for an S Corporation, for 1998. According to 3 Rev. Proc. 87-32, 1987-2 C.B. 396, was in effect in 1999 and 2000. It was superseded by Rev. Proc. 2002-38, 2002-1 C.B. 1037, effective for tax years ending on or after May 10, 2002.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011