Pelaez and Sons, Inc. - Page 6




                                        - 6 -                                         
               Additional citrus trees were planted during late 1991 (1991            
          trees), and the planting costs were capitalized and depreciated.            
          Based on the performance of the 1989 trees, it was believed that            
          the 1991 trees would be productive within their first 2 years.              
          The corporation, for its 1992 year and successive years, deducted           
          the developmental expenses and depreciation for the 1991 trees.             
               Respondent, in the FSAA notice, under section 263A,                    
          disallowed the following deductions claimed with respect to the             
          1989 and 1991 trees:                                                        
          Taxable year ended       1989 trees          1991 trees                     
          Sept. 30, 1991          1$1,171,949     -0-                                 
          Sept. 30, 1992           244,692             $90,513                        
          Sept. 30, 1993           -0-                 116,980                        
               1$649,126.11 of the amount claimed was paid in the 1991 tax            
          year and the remainder in the 1989 and 1990 tax years.                      
               Production History--1989 Trees--The 1989 trees bore blossoms           
          during early 1990, fruit was visible during the spring 1990, and            
          80 boxes of grapefruit were sold for $220, which was net of the             
          cost of harvest borne by the buyer.  The $220 of income was                 
          reported on the corporation’s 1991 return.  The 1989 trees were             
          affected by a 1989 frost, causing a loss of about 50 percent of             
          the grove.  The 1989 trees also bloomed in early 1991, and fruit            
          was visible during the spring of 1991.  The harvest began in                
          October 1991, and the corporation sold the second crop for                  
          approximately $14,600 net of the harvesting costs borne by the              
          buyer.                                                                      





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