- 7 - 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.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