- 3 - 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.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