- 2 - FINDINGS OF FACT Some of the facts have been stipulated, and the stipulation of facts and attached exhibits are incorporated herein by this reference. Petitioners resided in Lind, Washington, at the time of the filing of their petition. Petitioners timely filed their joint 1991 Federal income tax return with the Internal Revenue Service Center at Ogden, Utah. Petitioners reported their income using the cash method of accounting. During 1991, petitioners engaged in the business of farming. Specifically, they grew and sold grain. They have been in the business of farming for over 25 years. In October and November 1991, petitioners entered into deferred payment contracts (the contracts) with the Union Elevator Warehouse Co. (Union Elevator). Pursuant to the contracts, title to the grain passed to Union Elevator at the time of sale. However, petitioners contracted for payment to occur the following year. One of the contracts with Union Elevator, which is representative of all the contracts at issue, provides: The Seller agrees to sell and Buyer agrees to buy from Seller the following commodities and both agree to abide by the terms and conditions listed below: Quantity: 2,000 BU. Commodity: Soft white wheat Price: 4.00 Price basis: FOB whse Title passes on: 11-22-91 Payment date: Jan 1992Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011