Willamette Industries, Inc. v. Commissioner

118 T.C. No. 7

UNITED STATES TAX COURT WILLAMETTE INDUSTRIES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 20094-97, 7712-99. Filed February 12, 2002. Some of P’s trees were partially damaged and P was compelled to salvage the trees or they would have been lost through decay, insects, etc. The damage forced P to harvest the trees before intended. P had several alternatives for salvage and chose to process the damaged trees into the end products that it normally produces. P, under sec. 1033, I.R.C., seeks to defer only the portion of the gain attributable to the…