Jon W. and Kristi Nelson, et al. - Page 9




                                        - 9 -                                         
               The stated legislative purpose for the deferral of crop                
          insurance proceeds under section 451(d) was to allow farmers, in            
          and for the year they incur crop damage and receive insurance               
          proceeds, to avoid having to pay Federal income tax on 2 years’             
          worth of income relating to their crops (namely, income deferred            
          under their normal practice from the prior year into the current            
          year and also crop insurance proceeds received in the current               


               2(...continued)                                                        
               made by means of a statement attached to the taxpayer’s                
               return (or an amended return) for the taxable year of                  
               destruction or damage.  The statement shall include the                
               name and address of the taxpayer (or his duly                          
               authorized representative), and shall set forth the                    
               following information:                                                 
                    (i)  A declaration that the taxpayer is making an                 
               election under section 451(d) and this section;                        
                    (ii)  Identification of the specific crop or crops                
               destroyed or damaged;                                                  
                    (iii)  A declaration that under the taxpayer’s                    
               normal business practice the income derived from the                   
               crops which were destroyed or damaged would have been                  
               included in his gross income for a taxable year                        
               following the taxable year of such destruction or                      
               damage;                                                                
                    (iv)  The cause of destruction or damage of crops                 
               and the date or dates on which such destruction or                     
               damage occurred;                                                       
                    (v)  The total amount of payments received from                   
               insurance carriers, itemized with respect to each                      
               specific crop and with respect to the date each payment                
               was received;                                                          
                    (vi)  The name(s) of the insurance carrier or                     
               carriers from whom payments were received. [Emphasis                   
               added.]                                                                





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