Golden Rod Farms, Inc. v. United States

KRAVITCH, Senior Circuit Judge:

This case requires us to determine, as an issue of first impression, whether a corporation can qualify as a “farm-related taxpayer” within the meaning of 26 U.S.C. § 464(f)(3)(B) (1988). We conclude that Con gress intended “farm-related taxpayer” to include all taxpayers, whether corporations or individuals, who are engaged full-time in farming activities. We thus affirm the district court’s order granting Golden Rod Farms, Inc. (“Golden Rod”) summary judgment on its claim for a tax refund.

I

Golden Rod is an Alabama corporation that, as its primary business,…