Chapter 7 - Timber Casualty Loss Audit Techniques Guide

Publication Date: September 2005

NOTE: This guide is current through the publication date. Since changes may have occurred after the publication date that would affect the accuracy of this document, no guarantees are made concerning the technical accuracy after the publication date.

7. Computations

A. Loss Computation:
When a taxpayer makes a casualty loss claim that was in excess of cost basis recovery, then special computations must be made.

An IRS Forester should verify the before and after block fair market value loss prior to making this basis adjustment to reflect the loss of fair market value. The casualty loss allowed can never be larger than the adjusted depletion basis.

If a determination is made that the difference in the before and after fair market value loss is less than the basis in the timber depletion block, then the basis should be adjusted.

B. Reconciliation of Form T:
Line 23 on Part II of Form T, permits basis adjustments for casualty losses that exceed normal unit rate values per Rev. Rul. 99-56. Included in this dollar value may be basis reductions due to degradation of the existing timber or for values in excess of the unit rate basis.

C. Adjusting the Remaining Basis:
Many special circumstances can occur that may affect the way the remaining basis is allocated. Of course there is a finite basis pool to draw from, especially in regard to a taxpayer that has elected to deplete from different timber product sub-accounts (for example, saw timber, pulpwood, premerchantable, or reforestation accounts). How the loss is allocated depends on the size of the loss from each of the individual sub-accounts and the balance available in each sub-account. Consistent with the regulations, which allow an allocation of timber basis to the appropriate timber product classes (i.e. reproduction, premerchantable, pulpwood, saw timber), following are a series of circumstances and the recommended method for adjusting the basis:

1. The basis in each timber account is not exceeded:
This is the most straightforward of the possible scenarios. The fair market value diminution determined for each individual account is deducted from that account basis pool. This is accomplished on the line labeled "Allowable basis of loss" on line 23, column b of Part II of the current year's Form T, See Example 1 below.

2. The fair market diminution in one or more timber accounts exceeds the basis in those individual accounts:
In this scenario, when one account basis is written down to zero, the balance of the loss amount is allocated to the other timber accounts in proportion to their contributing value to the total remaining adjusted basis in the block. All accounts are adjusted for all casualties before this reallocation of the remaining loss is applied. See Example 2 below.

3. The loss was a result of product degradation:
The degradation claim can only be made if the timber will never be suitable for sale as a higher valued product.

The IRS Forester should take special care that if product degradation took place that the allowable deduction for value loss is taken from the basis of the source account and also that an adjustment is made to the target account. For example, if the saw timber was degraded to pulpwood, the affected volume should be transferred to the pulpwood account as a correction. This can be accomplished on line 12 of the depletion schedule for the Pine Pulpwood account. The allowable decrease for loss by degradation (loss net of basis) should be made to the saw timber account as a correction on line 23, column b of Part II of Form T. See Example 3 below.

D. Form T — Examples

Examples of required adjustments to the depletion account following casualty losses where the basis limitation is the entire block and not the individual timber unit (cord, ton, MBF, etc.) damaged or destroyed.

Example 1: The diminution in fair market does not exceed the basis in the respective sub accounts:

A forest products taxpayer experienced a casualty due to wildfires during the 2001 tax year. The merchantable timber that was burned was not salvaged. In addition to the merchantable timber losses the fire consumed 1,258 acres of a 1999 plantation. Following are the loss volumes and claimed dollar loss.

Pine Sawtimber 33,881 Cords FMV Decrease $3,469,414
Pine Pulpwood 37,926 Cords FMV Decrease $ 857,128
1999 Plantation 1,258 Cords FMV Decrease $ 515,780

With the issuance of Rev. Rul. 99-56 there were no guidelines on how to account for the additional basis deduction when the diminution in FMV is greater than the normally computed unit rate depletion. The following Part II of Form T demonstrates how the additional basis should be accounted for in the depletion schedule for each sub account to reduce the basis for the additional allowable basis deduction.

Pine Sawtimber Form T Account

NOTE: In the Pine Sawtimber (PST) account the allowable basis of loss using the unit rate calculation is recorded on line 23 of Form T. An additional basis deduction allowed as a result of Rev. Rul. 99-56 is determined by subtracting the allowable unit basis on line 23 of Form T from the claimed casualty loss difference in FMV of the SIP before the casualty and FMV of the SIP after the casualty for the appropriate timber account. The additional basis recovery pursuant to Rev. Rul. 99-56 is also recorded on line 23 of Form T. Additional basis adjustments are limited to the remaining basis in the SIP account.

Line No. Part II of Form T, Capital Returnable Through Depletion 2001
10

Name of block and title of account

Alabama Block, Pine Sawtimber (PST) account, units in Cords

Quantity in MBF, log scale, cords, or other unit 1 Cost or other basis
11 Estimated quantity of timber and amount of capital returnable through Depletion at end of the immediately preceding tax year 1,228,624 $26,587,423
12 Increase or decrease of quantity of timber required by way of correction 2 0
13a Addition for growth (period covered __one __ years) 6% growth rate 73,717
13b Transfers from premerchantable timber account 0 $0
13c Transfers from deferred reforestation account 0 $0
14 Timber Acquired during year 0 $0
15 Addition to capital during year 3 $0
16 Total at end of year, before depletion (add lines 11 thru 15, in each column) 1,302,341 $26,587,423
17 Unit rate returnable through depletion, or basis of sales or losses $ 20.42
18 Quantity of timber cut during the year 0
19 Depletion sustained (line 17 multiplied by line 18) $0
20 Quantity of standing timber sold or otherwise disposed of during the year 0
21 Allowable as basis of sale (line 17 multiplied by line 20) $0
22 Quantity of standing timber lost by fire or other cause during year 33,881
23 Allowable basis of loss (line 17 multiplied by line 22) plus additional basis recovery per Rev. Rul. 99-56 4 $3,469,414
24 Total Reductions during year:
24a Add line 18, column a, line 20 column a, and line 22 column a 33,881
24b Add line 19 column b, line 21 column b, and line 23 column b $3,469,414
25 Net quantity and value at end of year (line 16 column a less line 24a and line 16 column b less the sum of line 24b) 1,268,460 $23,118,009
1 If MBF, log scale, is not the unit used, state what unit is used and explain its derivation.
2 Adjust the quantity in MBF, log scale, or other unit remaining a the end of the year for changes in reinventory, standards of use, scattered and/or indefinitely ascertained losses, inaccuracy of the former estimate, or change in the log scale if the log rule now in use differs from the one used as basis for depletion in earlier yeas. If you make a change, state clearly the basis for it.
3 Analyze the addition to show the individual items included. Include expenditures for taxes, administration, protection, interest actually paid, etc., if you did not treat these expenditures as expense deductions on your return. Carry expenditures for reforestation, such as site preparation, planting, seeding, etc., in a separate deferred account.
4 Difference in FMV of SIP before the casualty and FMV of SIP after the casualty less the allowable unit basis of loss. Additional basis is limited to the remaining basis in the SIP (block).

Pine Pulpwood Form T Account

NOTE: The following schedule demonstrates how the pine pulpwood account would be adjusted for the loss. This is similar to adjustments in the Pine Sawtimber (PST) account shown above.

Line No. Part II of Form T, Capital Returnable Through Depletion 2001
10

Name of block and title of account

Alabama Block, Pine Pulpwood (PPW) account, units in Cords

Quantity in MBF, log scale, cords, or other unit 1

Cost or other basis

11 Estimated quantity of timber and amount of capital returnable through Depletion at end of the immediately preceding tax year 867,321 $1,967,593
12 Increase or decrease of quantity of timber required by way of correction 2 0
13a Addition for growth (period covered __one __ years) 6% growth rate 52,039
13b Transfers from premerchantable timber account 0 $0
13c Transfers from deferred reforestation account 0 $0
14 Timber Acquired during year 0 $0
15 Addition to capital during year 3 $0
16 Total at end of year, before depletion (add lines 11 thru 15, in each column) 919,360 $1,967,593
17 Unit rate returnable through depletion, or basis of sales or losses $ 2.14
18 Quantity of timber cut during the year 0
19 Depletion sustained (line 17 multiplied by line 18) $0
20 Quantity of standing timber sold or otherwise disposed of during the year 0
21 Allowable as basis of sale (line 17 multiplied by line 20) $0
22 Quantity of standing timber lost by fire or other cause during year 37,926
23 Allowable basis of loss (line 17 multiplied by line 22) plus additional basis recovery per Rev. Rul. 99-56 4 $ 857,128
24 Total Reductions during year:
24a Add line 18, column a, line 20 column a, and line 22 column a 37,926
24b Add line 19 column b, line 21 column b, and line 23 column b
25 Net quantity and value at end of year (line 16 column a less line 24a and line 16 column b less the sum of line 24b) 881,434 $1,110,465
1 If MBF, log scale, is not the unit used, state what unit is used and explain its derivation.
2 Adjust the quantity in MBF, log scale, or other unit remaining a the end of the year for changes in reinventory, standards of use, scattered and/or indefinitely ascertained losses, inaccuracy of the former estimate, or change in the log scale if the log rule now in use differs from the one used as basis for depletion in earlier yeas. If you make a change, state clearly the basis for it.
3 Analyze the addition to show the individual items included. Include expenditures for taxes, administration, protection, interest actually paid, etc., if you did not treat these expenditures as expense deductions on your return. Carry expenditures for reforestation, such as site preparation, planting, seeding, etc., in a separate deferred account.
4 Difference in FMV of SIP before the casualty and FMV of SIP after the casualty less the allowable unit basis of loss. Additional basis is limited to the remaining basis in the SIP (block).

The following Deferred Reforestation account demonstrates how the basis adjustment would be made to the reforestation plantation account following a casualty loss claim.

NOTE: Allowable Basis in acres lost to the casualty would be computed by multiplying the Seedling Planting Cost/Acre in column D times the number of Loss Acres destroyed in column E, results in the Basis of Loss in column F.
NOTE: Column G contains the Claimed Casualty Loss for the pine plantation acres that represent the diminution in FMV before and after the casualty. This column will almost always exceed the normal Basis of Loss represented in column F.
NOTE: Since Rev. Rul. 99-56 allows for greater than the unit basis recovery, column H represents the Additional Basis Per Rev. Rul. 99-56 recovered from the plantation account. This is computed by subtracting the Basis of Loss in column F from the Claimed Casualty Loss in column G.
NOTE: Column I is the remaining basis or Ending Deferred Reforestation in each year's plantation account after subtracting the Basis of Loss and the Additional Basis Per Rev. Rul. 99-56 from the Beginning Deferred Reforestation in column B.

Deferred Reforestation Account

A

B

C

D

E

F

G

H

I

Beginning Seedling Claimed Additional Ending
Vintage Deferred Beginning Planting Loss Basis of Casualty Basis per Deferred
Year Reforestation Acres Cost/Acre Acres Loss Loss RR 99-56 Reforestation
1986 $343,505 15,111 $22.73 $0 $343,505
1987 $3,306469 14,749 $224.18 $0 $3,306469
1988 $3,357,244 20,581 $163.12 $0 $3,357,244
1989 $3,972,567 25,429 $156.22 $0 $3,972,567
1990 $4,785,181 23,703 $201.88 $0 $4,785,181
1991 $3,705,598 15,204 $243.73 $0 $3,705,598
1992 $3,518,339 12,599 $279.26 $0 $3,518,339
1993 $4,951,240 26,054 $190.04 $0 $4,951,240
1994 $4,479,524 20,534 $218.15 $0 $4,479,524
1995 $6,776,708 36,390 $186.22 $0 $6,776,708
1996 $6,183,699 45,045 $137.28 $0 $6,183,699
1997 $4,816,581 37,073 $129.92 $0 $4,816,581
1998 $4,860,300 31,401 $154.78 $0 $4,860,300
1999 $3,667,523 30,339 $120.88 1,258 $152,073 $515,780 $363,707 $3,151,743
2000 $4,611,852 28,967 $159.21 $0 $4,611,852
2001 $9,079,508 39,982 $227.09 $0 $9,079,508
Total $72,415,838 423,161 $152,073 $515,780 $363,707 $71,900,058

Example 2: The fair market diminution in one or more timber sub-accounts exceeds the basis in those individual accounts:

In this scenario, when one sub-account basis is written down to zero, the balance of the allowable loss is allocated to the other timber sub-accounts. For instance, if the basis in the pulpwood account is exceeded by a FMV loss claim then the additional basis recovery must come from another merchantable timber sub-account.

The same forest products taxpayer in Example 1 experienced several more fires in 2002. However, the fires only destroyed stands of timber containing pine pulpwood (PPW). The taxpayer lost 147,651 cords of PPW. The diminution in value of the block (the SIP) as a result of this loss was $2,362,416. The following entries in the Part II of Form T would be necessary to account for the basis recovery as a result of the loss.

  1. The PPW account beginning balances for 2002 reflect the ending balances from 2001.
  2. Notice that the total basis remaining in the PPW account is not sufficient to cover the loss of $2,362,416. The basis in this sub-account has been exceeded but not the basis in the entire block (the SIP).
  3. The additional basis recovery must come from another merchantable timber account, preferably of the same species. In this case, the basis will be taken from the Pine sawtimber (PST) account.
  4. Note how the loss is taken from the PST account on Part II of Form T for the Pine Sawtimber account for 2002.

Pine Pulpwood Account

Line No. Part II of Form T, Capital Returnable Through Depletion 2002
10

Name of block and title of account

Alabama Block, Pine Pulpwood account, units in Cords

Quantity in MBF, log scale, cords, or other unit 1

Cost or other basis

11 Estimated quantity of timber and amount of capital returnable through Depletion at end of the immediately preceding tax year 881,434 $1,110,465
12 Increase or decrease of quantity of timber required by way of correction 2 0
13a Addition for growth (period covered __one __ years) 6% growth rate 52,886
13b Transfers from premerchantable timber account 0 $0
13c Transfers from deferred reforestation account 0 $0
14 Timber Acquired during year 0 $0
15 Addition to capital during year 3 $0
16 Total at end of year, before depletion (add lines 11 thru 15, in each column) 934,320 $1,110,465
17 Unit rate returnable through depletion, or basis of sales or losses $ 1.19
18 Quantity of timber cut during the year 0
19 Depletion sustained (line 17 multiplied by line 18) $0
20 Quantity of standing timber sold or otherwise disposed of during the year 0
21 Allowable as basis of sale (line 17 multiplied by line 20) $0
22 Quantity of standing timber lost by fire or other cause during year 147,651
23 Allowable basis of loss (line 17 multiplied by line 22) plus additional basis recovery per Rev. Rul. 99-56 4 $1,110,465
24 Total Reductions during year:
24a Add line 18, column a, line 20 column a, and line 22 column a 147,651
24b Add line 19 column b, line 21 column b, and line 23 column b
25 Net quantity and value at end of year (line 16 column a less line 24a and line 16 column b less the sum of line 24b) 786,669 $0
1 If MBF, log scale, is not the unit used, state what unit is used and explain its derivation.
2 Adjust the quantity in MBF, log scale, or other unit remaining a the end of the year for changes in reinventory, standards of use, scattered and/or indefinitely ascertained losses, inaccuracy of the former estimate, or change in the log scale if the log rule now in use differs from the one used as basis for depletion in earlier yeas. If you make a change, state clearly the basis for it.
3 Analyze the addition to show the individual items included. Include expenditures for taxes, administration, protection, interest actually paid, etc., if you did not treat these expenditures as expense deductions on your return. Carry expenditures for reforestation, such as site preparation, planting, seeding, etc., in a separate deferred account.
4 Difference in FMV of SIP before the casualty and FMV of SIP after the casualty less the allowable unit basis of loss. Additional basis is limited to the remaining basis in the SIP (block).

NOTE: Line 23 reflects the additional basis recovery per Rev. Rul. 99-56 that was transferred from the PPW account due to insufficient basis in that account to cover the casualty loss.

NOTE: There was no activity in the PST account during 2002; however, this account was reduced by $1,251,951 as a result of the PPW casualty loss.

Pine Sawtimber Account

Line No. Part II of Form T, Capital Returnable Through Depletion 2002
10

Name of block and title of account

Alabama Block, Pine Sawtimber (PST) account, units in Cords

Quantity in MBF, log scale, cords, or other unit 1

Cost or other basis

11 Estimated quantity of timber and amount of capital returnable through Depletion at end of the immediately preceding tax year 1,268,460 $23,118,009
12 Increase or decrease of quantity of timber required by way of correction 2 0
13a Addition for growth (period covered __one __ years) 6% growth rate 76,108
13b Transfers from premerchantable timber account 0 $0
13c Transfers from deferred reforestation account 0 $0
14 Timber Acquired during year 0 $0
15 Addition to capital during year 3 $0
16 Total at end of year, before depletion (add lines 11 thru 15, in each column) 1,344,568 $23,118,009
17 Unit rate returnable through depletion, or basis of sales or losses $ 17.19
18 Quantity of timber cut during the year 0
19 Depletion sustained (line 17 multiplied by line 18) $0
20 Quantity of standing timber sold or otherwise disposed of during the year 0
21 Allowable as basis of sale (line 17 multiplied by line 20) $0
22 Quantity of standing timber lost by fire or other cause during year 0
23 Allowable basis of loss (line 17 multiplied by line 22) plus additional basis recovery per Rev. Rul. 99-56 4 $1,251,951
24 Total Reductions during year:
24a Add line 18, column a, line 20 column a, and line 22 column a 0
24b Add line 19 column b, line 21 column b, and line 23 column b $0
25 Net quantity and value at end of year (line 16 column a less line 24a and line 16 column b less the sum of line 24b) 1,344,568 $21,866,058
1 If MBF, log scale, is not the unit used, state what unit is used and explain its derivation.
2 Adjust the quantity in MBF, log scale, or other unit remaining a the end of the year for changes in reinventory, standards of use, scattered and/or indefinitely ascertained losses, inaccuracy of the former estimate, or change in the log scale if the log rule now in use differs from the one used as basis for depletion in earlier yeas. If you make a change, state clearly the basis for it.
3 Analyze the addition to show the individual items included. Include expenditures for taxes, administration, protection, interest actually paid, etc., if you did not treat these expenditures as expense deductions on your return. Carry expenditures for reforestation, such as site preparation, planting, seeding, etc., in a separate deferred account.
4 Difference in FMV of SIP before the casualty and FMV of SIP after the casualty less the allowable unit basis of loss. Additional basis is limited to the remaining basis in the SIP (block).

Example 3: Casualty loss resulting from product degradation:

The degradation claim can only be made if the timber will never be suitable for sale as a higher valued product.

The IRS Forester should take special care that if product degradation took place that the allowable deduction for value loss is taken from the basis of the source account and also that an adjustment in volume is made to the target account. For example, if the saw timber was degraded to pulpwood, the affected volume should be transferred to the pulpwood account as a correction. This can be accomplished by decreasing the volume in the sawtimber account on line 22 and increasing the volume in the pulpwood account on line 12. The additional basis recovery, for the diminution in FMV by product degradation (loss net of depletion), should be made to the saw timber account on line 23.

The same forest products taxpayer in Example 1 experienced an ice storm in 2002. The ice storm resulted in product degradation from sawtimber to pulpwood. The affected volume of sawtimber was 43,253 cords which resulted in a FMV decrease in the block of $1,730,120. The following entries in Part II of Form T would be necessary to account for the basis recovery as a result of the loss.

  1. The PST account beginning balances for 2002 will reflect the ending balances from 2001.
  2. The volume of PST that was degraded will be listed as a loss in the PST account on line 22, column a. The associated reduction of depletion basis will appear on line 23, column b.
  3. The basis recovery will appear on line 23, column b of the PST account.
  4. The volume of PST degraded will be transferred to the PPW account as an addition on line 12, column a but there will be no basis associated with those units.

Pine Sawtimber Account

Line No. Part II of Form T, Capital Returnable Through Depletion 2002
10

Name of block and title of account

Alabama Block, Pine Sawtimber (PST) account, units in Cords

Quantity in MBF, log scale, cords, or other unit 1

Cost or other basis

11 Estimated quantity of timber and amount of capital returnable through Depletion at end of the immediately preceding tax year 1,268,460 $23,118,009
12 Increase or decrease of quantity of timber required by way of correction 2 0
13a Addition for growth (period covered __one __ years) 6% growth rate 76,108
13b Transfers from premerchantable timber account 0 $0
13c Transfers from deferred reforestation account 0 $0
14 Timber Acquired during year 0 $0
15 Addition to capital during year 3 $0
16 Total at end of year, before depletion (add lines 11 thru 15, in each column) 1,344,568 $23,118,009
17 Unit rate returnable through depletion, or basis of sales or losses $ 17.19
18 Quantity of timber cut during the year 0
19 Depletion sustained (line 17 multiplied by line 18) $0
20 Quantity of standing timber sold or otherwise disposed of during the year 0
21 Allowable as basis of sale (line 17 multiplied by line 20) $0
22 Quantity of standing timber lost by fire or other cause during year 43,253
23 Allowable basis of loss (line 17 multiplied by line 22) plus additional basis recovery per Rev. Rul. 99-56 4 $1,730,120
24 Total Reductions during year:
24a Add line 18, column a, line 20 column a, and line 22 column a 0
24b Add line 19 column b, line 21 column b, and line 23 column b $1,730,120
25 Net quantity and value at end of year (line 16 column a less line 24a and line 16 column b less the sum of line 24b) 1,301,315 $21,387,889
1 If MBF, log scale, is not the unit used, state what unit is used and explain its derivation.
2 Adjust the quantity in MBF, log scale, or other unit remaining a the end of the year for changes in reinventory, standards of use, scattered and/or indefinitely ascertained losses, inaccuracy of the former estimate, or change in the log scale if the log rule now in use differs from the one used as basis for depletion in earlier yeas. If you make a change, state clearly the basis for it.
3 Analyze the addition to show the individual items included. Include expenditures for taxes, administration, protection, interest actually paid, etc., if you did not treat these expenditures as expense deductions on your return. Carry expenditures for reforestation, such as site preparation, planting, seeding, etc., in a separate deferred account.
4 Difference in FMV of SIP before the casualty and FMV of SIP after the casualty less the allowable unit basis of loss. Additional basis is limited to the remaining basis in the SIP (block).

NOTE: Adjustments to the PPW account due to degradation of PST will result in an addition of units on line 12, column a.

Pine Pulpwood Account

Line No. Part II of Form T, Capital Returnable Through Depletion 2002
10

Name of block and title of account

Alabama Block, Pine Pulpwood (PPW) account, units in Cords

Quantity in MBF, log scale, cords, or other unit 1

Cost or other basis

11 Estimated quantity of timber and amount of capital returnable through Depletion at end of the immediately preceding tax year 881,434 $1,110,465
12 Increase or decrease of quantity of timber required by way of correction 2 43,253
13a Addition for growth (period covered __one __ years) 6% growth rate 52,886
13b Transfers from premerchantable timber account 0 $0
13c Transfers from deferred reforestation account 0 $0
14 Timber Acquired during year 0 $0
15 Addition to capital during year 3 $0
16 Total at end of year, before depletion (add lines 11 thru 15, in each column) 977,573 $1,110,465
17 Unit rate returnable through depletion, or basis of sales or losses $ 1.14
18 Quantity of timber cut during the year 0
19 Depletion sustained (line 17 multiplied by line 18) $0
20 Quantity of standing timber sold or otherwise disposed of during the year 0
21 Allowable as basis of sale (line 17 multiplied by line 20) $0
22 Quantity of standing timber lost by fire or other cause during year 0
23 Allowable basis of loss (line 17 multiplied by line 22) plus additional basis recovery per Rev. Rul. 99-56 4 $0
24 Total Reductions during year:
24a Add line 18, column a, line 20 column a, and line 22 column a 0
24b Add line 19 column b, line 21 column b, and line 23 column b $0
25 Net quantity and value at end of year (line 16 column a less line 24a and line 16 column b less the sum of line 24b) 977,573 $1,110,465
1 If MBF, log scale, is not the unit used, state what unit is used and explain its derivation.
2 Adjust the quantity in MBF, log scale, or other unit remaining a the end of the year for changes in reinventory, standards of use, scattered and/or indefinitely ascertained losses, inaccuracy of the former estimate, or change in the log scale if the log rule now in use differs from the one used as basis for depletion in earlier yeas. If you make a change, state clearly the basis for it.
3 Analyze the addition to show the individual items included. Include expenditures for taxes, administration, protection, interest actually paid, etc., if you did not treat these expenditures as expense deductions on your return. Carry expenditures for reforestation, such as site preparation, planting, seeding, etc., in a separate deferred account.
4 Difference in FMV of SIP before the casualty and FMV of SIP after the casualty less the allowable unit basis of loss. Additional basis is limited to the remaining basis in the SIP (block).

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