- 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,Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 NextLast modified: March 27, 2008