Archived Rulings
Useful definitions related to Revenue Rulings.
Capital Expenditures
Generally, direct costs incurred in connection with reforestation by planting are capital expenditures, recoverable through
depletion as the timber subsequently becomes merchantable and is cut or sold. Compare Mim. 6030, C. B. 1946-2, 45; G. C. M.
6544, C. B. VIII-2, 118 (1929). Superseded by Revenue Ruling 75-467.
Full Text: 55-252,
1955-1 C.B. 319
Capital Assets, holding period
For the purposes of section 117(h) of the Internal Revenue Code of 1939 relating to the determination of the period for which
property is held, the holding period of timber, acquired by a corporation (transferee) in a nontaxable exchange under section
112(b)(5) of the Code and subsequently cut by such corporation under the elective treatment accorded the cutting of timber
under section 117(k)(1) of the Code, includes the period during which such timber was held by the transferor. Compare G. C. B.
25301, C. B. 1947-2, 83.
Full Text: 55-352, 1955-1 C.B. 372
Losses
A loss arising from death of a tree as a result of disease or attack by insects does not constitute an allowable deduction as
a casualty loss within the meaning of section 165(c) of the Internal Revenue Code of 1954 or section 23(e)(3) of the Internal
Revenue Code of 1939.
Full Text: 57-599, 1957-2 C.B. 142
Involuntary conversion
Gain from the voluntary sale of timber uprooted by a hurricane does not qualify for the nonrecognition of gain provisions of
section 1033(a) of the Code even though the proceeds are used to purchase other standing timber. Revoked by Revenue Ruling 80-175.
Full Text: 72-372,
1972-2 C.B. 471
Revenue Rulings, review
Consistent with the program for the review of rulings published in the Internal Revenue
Bulletin before 1953 (announced by Revenue Procedure 67-6, C.B. 1967-1, 576), the Internal Revenue Service has undertaken a review
of certain rulings that were published in the Bulletin after 1952. The purpose of this Revenue Ruling is to publish a list of
post-1952 rulings dealing primarily with engineering matters and with income and profits taxes that, although not specifically
revoked or superseded, are not considered determinative with respect to future transactions.
Full Text: 72-620,
1972-2 C.B. 651
Inventories
Accrual-method taxpayers operating farms, nurseries, and florist shops must inventory growing crops,
trees, and plants, respectively, unless the taxpayer uses the crop method of accounting in computing gross income; I.T. 1368 and
O.D. 995 revoked. Revoked by Revenue Ruling 79-102; modified by Revenue Ruling 77-64.
Full Text: 76-242,
1976-1 C.B. 132
Revenue Rulings, review
Rev. Proc. 67-6, 1967-1 C.B. 576, announced a program for the review of rulings published before 1953 with the immediate objective
of identifying and publishing lists of those rulings that, although not specifically revoked or superseded, are not considered
determinative with respect to future transactions.
Full Text: 76-566,
1976-2 C.B. 450
Forestry Incentives Program, reimbursements
Cost sharing payments received from the Federal government under the
forestry incentives program of the Agriculture and Consumer Protection Act of 1973 are includible in income, and the total costs
of reforestation (not diminished by such payments) are to be capitalized as a cost of timber. Superseded by Revenue Ruling 84-67.
Full Text: 76-6, 1976-1
C.B. 176
Inventories
Rev. Rule. 76-242, 1976-1 C.B. 132, provides that for the purpose of computing gross income: (1) farmers
using an accrual method of accounting must inventory growing crops; (2) a taxpayer operating a nursery using an accrual method of
accounting must inventory growing trees; and (3) florists using an accrual method of accounting must inventory growing plants,
unless such taxpayer uses the crop method. Revoked by Revenue Ruling 79-102.
Full Text: 77-64, 1977-1
C.B. 136