Legal Opinion

Hi-Plains Enterprises, Inc. v. Commissioner

United States Tax Court

Decided April 30, 1973No. Docket No. 7923-70PublishedCited by 21 opinions

A corporation engaged in custom-finishing livestock in feedlots is a farmer within the meaning of sec. 1.61-4(d), Income Tax Regs., and is entitled to file Federal income tax returns on the cash basis even though the corporate books are kept on the accrual basis. Sec. 1.471-6(a), Income Tax Regs.

1Opinion of the Court

Tietjens, Judge:

The Commissioner determined deficiencies in the corporate income tax of petitioner for the taxable years 1966, 1967, and 1968 as follows:

Year Deficiency

I960 - $2,186. 81

1967 - 62, 521. 69

1968 '- 279,192.96

Total _ 343, 901. 46

This case concerns the method of accounting employed by petitioner for tax purposes. The entire amounts of the deficiencies are in dispute.

FINDINGS OF FACT

Some of the facts are stipulated and are so found.

Hi-Plains Enterprises, Inc., is a Kansas corporation, organized March 1, 1966, which owns and operates a feedlot located in Leoti, Kans., its principal…

2Cases cited10 opinions

  1. United States v. Jefferson Electric Manufacturing Co.Supreme Court of the United States · 1934
  2. United States v. CattoSupreme Court of the United States · 1966
  3. Louis Spitalny and Betty Spitalny, His Wife v. United States of America, William Erdwurm and Bart F. Erdwurm, His Wife v. United StatesCourt of Appeals for the Ninth Circuit · 1970
  4. Garth v. CommissionerUnited States Tax Court · 1971
  5. Stokes v. CommissionerUnited States Tax Court · 1954

5 more not listed; retrieve them via the Exa API.

3Cited by21 opinions

  1. Van Raden v. CommissionerUnited States Tax Court · 1979
  2. Packard v. CommissionerUnited States Tax Court · 1985
  3. Hi-Plains Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1974
  4. Maple Leaf Farms, Inc. v. CommissionerUnited States Tax Court · 1975
  5. Rojas v. CommissionerUnited States Tax Court · 1988

16 more not listed; retrieve them via the Exa API.

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