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Willamette Industries, Inc. v. Commissioner

United States Tax Court
118 T.C. 126 (2002)


Facts

Willamette Industries, Inc. (Willamette) (plaintiff) grew, harvested, and processed trees for commercial sale and use. Willamette’s business required the trees to reach maturity before they were harvested and processed. Some of Willamette’s trees were damaged by insects and bad weather before reaching maturity. Willamette prematurely harvested the damaged trees. Instead of selling the harvested trees in their unprocessed condition, Willamette processed the trees and sold the resulting products as if the trees had been mature. Willamette regarded the trees’ damage, processing, and sale as an involuntary conversion under § 1033 of the federal tax code. Willamette contended that § 1033 allowed it to defer some of its taxable gain on the processing and sale of the damaged trees. The commissioner of internal revenue (commissioner) (defendant) determined that there had been no involuntary conversion under § 1033, because Willamette had processed and sold the damaged trees as usual rather than selling the trees in an unprocessed condition. Willamette petitioned the tax court for a redetermination.

Rule of Law

Issue

Holding and Reasoning (Gerber, J.)

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