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explicitly, and intentionally” permit petitioner’s use of the
cash method.
C. Section 1.471-6(a), Income Tax Regs.--Whether
Petitioner Is a “Farmer”
Petitioner cites various cases in which we held that the
taxpayers were farmers and thus were entitled to use the cash
method. In Maple Leaf Farms, Inc. v. Commissioner, 64 T.C. 438
(1975), we held that a duck grower was entitled to use the cash
method under section 1.471-6(a), Income Tax Regs. We looked to
other sections to determine whether the duck grower was a
“farmer” and whether the place where the duck growing process
occurred was a “farm” for purposes of section 1.471-6(a), Income
Tax Regs. Id. at 447 (citing sections 175(c)(2), 180(b),
182(c), and 6420(c)(2) and (3) and sections 1.61-4(d), 1.175-3,
1.180-1(b), and 1.182-2, Income Tax Regs.). In Maple Leaf
Farms, Inc., the facts evidenced that the taxpayer was
integrally involved in the process of growing ducks it raised on
its own property and in the process of growing ducks it supplied
to independent growers. Id. The taxpayer also bore a
substantial risk of loss. Id. at 448. Thus, the taxpayer’s
“participation in the activities of its growers was sufficient
to constitute it a ‘farmer’ and accordingly it may use the cash
receipts and disbursements method of accounting in respect of
its ducks.” Id. at 452; see also sec. 1.471-6(a), Income Tax
Regs.
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