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Production History--1991 Trees--There were blooms on the
1991 trees during early 1993, fruit was visible during the spring
1993, and the corporation sold the fruit from the harvest
beginning in October 1993. Fruit from the 1991 trees won an
award, based on size and quality, in a 1993 county fair.
The corporation, for the taxable periods 1991 through 1994,
harvested and sold boxes of fruit as follows:
Tangerines/
Taxable year ended Oranges Grapefruit tangelos
Sept. 30, 1991 -0- 80 -0-
Sept. 30, 1992 4,465 967 118
Sept. 30, 1993 28,906 30,439 3,469
Sept. 30, 1994 36,242 36,836 9,413
Production information for 1989 trees and 1991 trees was not
segregated.
During October 1993, a group described as the “Florida
Citrus Liaison Team” was formed, and it consisted of five citrus
industry representatives, two tax practitioners, and six
representatives from the Internal Revenue Service (IRS). The
IRS’ Specialization Program coordinator (for the citrus industry)
was a participant in the liaison group. The group sought
guidance from the Office of Chief Counsel of the IRS with respect
to issues concerning section 263A. There was a belief within the
liaison group that IRS examiners were not uniformly applying the
section 263A provisions.
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Last modified: May 25, 2011