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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...)
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