Hi-Plains Enterprises, Inc. v. Commissioner of Internal Revenue

PICKETT, Circuit Judge.

For the years 1966, 1967 and 1968, Hi-Plains Enterprises, Inc., a Kansas corporation engaged in the business of feeding cattle for market, filed its income tax return on a cash method of accounting. The Commissioner of Internal Revenue concluded that the taxpayer was not a “farmer” and its business was such that its income should be determind on an accrual basis. Consequently, substantial deficiencies were assessed against the taxpayer. On petition for redetermination, the Tax Court found that the taxpayer’s operations were those of a farmer, which permitted it to elect…