Willamette Industries, Inc. - Page 7




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          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.                                                  






















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Last modified: May 25, 2011