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fruits, or other agricultural products, or for the sustenance of
livestock.” Under the facts of this case, petitioner does not
use the woodland it owns to produce crops, fruits, or other
agricultural products. Likewise, in sections 1.182-2 and 1.175-
3, Income Tax Regs., “A taxpayer is engaged in the business of
farming if he cultivates, operates, or manages a farm for gain
or profit * * * A taxpayer engaged in forestry or the growing of
timber is not thereby engaged in the business of farming.”8
Indeed, these regulations specifically exclude petitioner from
the definition of “business of farming” for purposes of those
sections.
Petitioner engages in a variety of business activities.
Petitioner’s business activities do not qualify petitioner as a
“farmer” for purposes of section 1.471-6(a), Income Tax Regs.
Further, some of petitioner’s business activities specifically
require it to maintain inventories. Thus, section 1.471-6(a),
Income Tax Regs., does not permit petitioner’s use of the cash
method under the facts and circumstances presented herein.
8 We note that the other sections cited in Maple Leaf
Farms, Inc. v. Commissioner, 64 T.C. 438 (1975), provide similar
definitions for “farming” and “the business of farming”.
Petitioner does not meet these definitions either. See secs.
180(b), 6420(c)(2) and (3); secs. 1.61-4(d), 1.180-1(b), Income
Tax Regs.
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