- 7 - petitioner contends that it was compelled (in order to avoid further damage or loss) to salvage (process) the damaged trees resulting in an involuntary conversion within the meaning of section 1033. Petitioner also points out that the conversion was “involuntary” because the damaged trees were not scheduled for harvest at the time of the damage. In response to respondent’s argument, petitioner contends that its choices for salvaging the damaged trees should not preclude deferral of the portion of the gain that it was compelled to realize on account of the damage to its trees. Petitioner emphasizes that it is not attempting to defer gain from processing and/or milling the damaged trees. Petitioner seeks to defer only that portion of the gain attributable to the difference between its basis in the damaged trees and their fair market value at the time the process of salvaging the trees began.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