Jon W. and Kristi Nelson, et al. - Page 4




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               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 of             







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