Legal Opinion

Maple Leaf Farms, Inc. v. Commissioner

United States Tax Court

Decided June 19, 1975No. Docket No. 8314-73PublishedCited by 20 opinions

Held, since petitioner participated sufficiently in the process and risk of loss involved in growing ducks, it qualifies as a farmer within the meaning of sec. 1.471-6(a), Income Tax Regs., and therefore is entitled to file its income tax returns on the cash receipts and disbursements method of accounting.

1Opinion of the Court

Tannenwald, Judge:

Respondent determined the following deficiencies in petitioner’s Federal income tax:

TYENov.30— Amount

1967_ $240,921.60

1968_ 82,394.01

1969_ 154,122.63

Other issues having been settled, the only issue for our determination is whether petitioner is a farmer, as opposed to a processor, and is therefore entitled to report its income by the cash receipts and disbursements method instead of the accrual method of accounting in accordance with section 1.471-6(a), Income Tax Regs.1

FINDINGS OF FACT

Certain facts have been stipulated and are found accordingly. The stipulation of facts and…

2Cases cited11 opinions

  1. United States v. CattoSupreme Court of the United States · 1966
  2. Auburn Packing Co. v. CommissionerUnited States Tax Court · 1973
  3. Garth v. CommissionerUnited States Tax Court · 1971
  4. Stokes v. CommissionerUnited States Tax Court · 1954
  5. Hi-Plains Enterprises, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1974

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

3Cited by20 opinions

  1. Van Raden v. CommissionerUnited States Tax Court · 1979
  2. Packard v. CommissionerUnited States Tax Court · 1985
  3. Duggar v. CommissionerUnited States Tax Court · 1978
  4. Rocco, Inc. v. CommissionerUnited States Tax Court · 1979
  5. Kennedy v. CommissionerUnited States Tax Court · 1987

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

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