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cannot define that term as broadly in the context of petitioner's
Tobacco Barn. The distinction lies in the fact that the Tobacco
Barn was not used in the production of mushrooms. Congress chose
that in the context of mushroom production, a single purpose
horticultural structure would be any "structure" specifically
designed and constructed for that purpose, whereas in the context
of plant production, a single purpose horticultural structure
would be any "greenhouse" specifically designed and constructed
for that purpose. See sec. 168(i)(13)(B)(ii). By using the word
"greenhouse", we think that Congress intended that only "plant"
production activities of the type performed in a "greenhouse"
would qualify as plant production activities. Thus, petitioners'
Tobacco Barn, a structure other than a greenhouse, used in the
curing, stripping, grading, baling, and boxing of tobacco--
activities which we think constitute market preparation--does not
meet the "exclusive use" test.
In addition, the Tobacco Barn was extensively used in making
the tobacco ready for market. As mentioned, work space in a
single purpose horticultural structure must be limited to that
necessary to stock, care for, or collect plants or their
products. See sec. 168(i)(13)(B)(iii). As provided by section
1.48-10(f)(2), Income Tax Regs., the term "stocking, caring for,
or collecting" plants includes ancillary postproduction
activities.
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