- 4 - The books and records of WJS-LLP and of WJS-Partnership were maintained and their Federal income tax returns were filed using the cash method of accounting. Each year, however, for Federal income tax purposes income from the harvest and sale of sugar beet crops was and is reported by WJS-LLP and by WJS-Partnership not on the basis of when the partnerships sell the crops, receive the proceeds, or realize the income therefrom but rather on the basis of the following formula: 65 percent of the income realized from the sale of the sugar beet crops is reported in the year of the harvest of the crops, and the remaining 35 percent is reported in the year following the harvest. Consistently, on information tax returns, Forms 1065, U.S. Return of Partnership Income, submitted to respondent each year, WJS-LLP and WJS-Partnership allocate among petitioners herein the income from the harvest and sale of sugar beet crops not on the basis of when the partnerships receive the proceeds or realize income from the sale of the sugar beet crops, but rather on the basis of the above formula: namely, 65 percent in the year of harvest and 35 percent in the year following the harvest. If WJS-LLP’s and WJS-Partnership’s 2001 sugar beet crops had not been destroyed and if the crops had been sold in 2001, for 2001 WJS-LLP and WJS-Partnership would have allocated to petitioners and reported to respondent a total of 65 percent ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008