CONSTRUCTIVE RECEIPT OF INCOME UNDER
FARM BILL 2002

Most farm operators and peanut quota owners are cash-basis taxpayers. For cash-basis taxpayers, Treasury Department regulation (Sec. 1.451-2(a) states that income is considered to be received by the taxpayer when it becomes available to him, regardless of whether it is in his possession.

To clarify the issue of constructive receipt with respect to production flexibility contract (PFC) payments in the 1996 Farm Bill, Congress stated:

"Any option to accelerate the receipt of any payment under production flexibility contract which is payable under the Federal Agriculture Improvement and Reform Act of 1996 (7 U.S.C. 7200 [7201] et seq.), as in effect on the date of the enactment of this Act [Dec. 17, 1999], shall be disregarded in determining the taxable year for which such payment is properly includible in gross income for purposes of the Internal Revenue Code of 1986 {26 U.S.C. 1 et seq]."

Congress made notice with the above statement that PFC payments would be included in the taxable income of recipients in the year they were received by taxpayers.

In Farm Bill 2002, Congress made the following statements.

With Regard to Direct Payments:

"At the option of the producers on a farm, up to 50 percent of the direct payment for any of the 2003 through 2007 crop years shall be paid to the producers in advance. The producers shall select the month within which the advance payment for a crop year will be made. The month selected may be any month during the period beginning on December 1 of the calendar year before the calendar year in which the crop is harvested through the month within which the direct payment would otherwise be made." (Italics added)

With Regard to Peanut Quota Buyout Program Payments:

TIME FOR PAYMENT-

(1) PAYMENT IN INSTALLMENTS- The payments required under the contracts shall be provided in 5 equal installments not later than September 30 of each of fiscal years 2002 through 2006.

(2) SINGLE PAYMENT- At the request of an eligible peanut quota holder entitled to payments under a contract, the Secretary shall provide the entire payment amount determined under subsection (d) with respect to the eligible peanut quota holder for the 5 fiscal years in a single lump sum during the fiscal year specified by the eligible peanut quota holder. (Italics added)

By comparing the statement from the 1996 Farm Bill and the statements from Farm Bill 2002, it can be seen that it is the intent of Congress to allow taxpayers to report Direct Payments and Peanut Quota Buyout Program Payments in the year which they are actually received.

Prepared by:

Keith D. Kightlinger, Extension Economist - Farm Management
Department of Agricultural and Applied Economics
Cooperative Extension Service, The University of Georgia

September 4, 2002

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