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respondent is precluded from making any adjustment concerning the
corporation’s 1991 taxable year due to the expiration of the
limitation period.
FINDINGS OF FACT2
Pelaez and Sons, Inc., a Florida corporation, was
incorporated during 1955 and has continuously had its principal
place of business and engaged in commercial farming, through the
time of trial, in the State of Florida. Since 1989, S
corporation status has been elected for Federal tax purposes, and
the corporation was a cash basis taxpayer for the years under
consideration.
Beginning in 1955, the corporation engaged in commercial
cattle ranching and during the early 1960’s began raising sugar
cane. In the late 1980’s the corporation entered into citrus
growing operations to increase profits and minimize risk by means
of diversification. After successfully accelerating the
reproduction time in its cattle-raising activity, the
corporation, in a favorable citrus market, attempted to
accelerate the production of citrus crops. The land to be used
for the citrus grove had been used for cattle grazing, which made
it most suitable for citrus production.
2 The parties’ stipulation of facts and the attached
exhibits are incorporated by this reference.
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