- 8 - regulations under section 451(d) do use the definite article and refer to “the” income from crops. Section 1.451-6(a)(1), Income Tax Regs., provides in relevant part as follows: § 1.451-6. Election to include crop insurance proceeds in gross income in the taxable year following the taxable year of destruction or damage.--(a) In general.--(1) For taxable years ending after December 30, 1969, a taxpayer reporting gross income on the cash receipts and disbursements method of accounting may elect to include insurance proceeds received as a result of the destruction of, or damage to, crops in gross income for the taxable year following the taxable year of the destruction or damage, if the taxpayer establishes that, under the taxpayer’s normal business practice, the income from those crops would have been included in gross income for any taxable year following the taxable year of the destruction or damage. * * * [Emphasis added.] Similarly, with regard to the time and manner of making an election to defer crop insurance proceeds, section 1.451- 6(b)(1)(iii), Income Tax Regs., uses the definite article and refers to “the” income.2 2 Sec. 1.451-6(b)(1), Income Tax Regs., provides in part as follows: § 1.451-6. Election to include crop insurance proceeds in gross income in the taxable year following the taxable year of destruction or damage.-- * * * * * * * (b)(1) Time and manner of making election.–-The election to include in gross income insurance proceeds received as a result of destruction of, or damage to, the taxpayer’s crops in the taxable year following the taxable year of such destruction or damage shall be (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008