Jon W. and Kristi Nelson, et al. - Page 10




                                       - 10 -                                         
          year).  The 1969 Senate committee report explaining the policy              
          underlying section 451(d) makes it clear that Congress’ intent              
          was to provide a deferral of insurance proceeds in those                    
          situations where the farmers were not receiving (and therefore,             
          under their cash method of accounting, were not reporting) any              
          income from current year crops until the following year when the            
          crops were sold.  S. Rept. 91-552, at 106-107 (1969), 1969-3 C.B.           
          423, 492; see also H. Conf. Rept. 91-782, at 299 (1969), 1969-3             
          C.B. 644, 657.                                                              
               The Senate report provides the following explanation:                  

               General reasons for change.--The requirement of                        
               present law that crop insurance proceeds must be                       
               included in income for the year of receipt in the case                 
               of taxpayers using a cash method of accounting results                 
               in a hardship where it is the normal practice of the                   
               farmer to sell his crop in the year following that in                  
               which it is raised.  In this case the farmer normally                  
               would include the proceeds from the sale of the prior                  
               year’s crop in income for the taxable year and would                   
               include the proceeds from the sale of the current                      
               year’s crop in income for the following year when the                  
               crop is sold.  If, however, the current year’s crop is                 
               damaged or destroyed, for instance by hail or windstorm                
               and the farmer receives insurance proceeds to cover the                
               loss, he must include the insurance proceeds in income                 
               for the current year.  Thus, two years income must be                  
               reported in the current year as a result of an                         
               occurrence over which the farmer has no control. [S.                   
               Rept. 91-552, supra at 106-107, 1969-3 C.B. at 492.]                   

               As stated, under normal practice WJS-LLP, WJS-Partnership,             
          and petitioners did not report “the” income from the current                
          year’s sugar beet crops in the following year.  Rather, WJS-LLP,            







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