For farm and ranch taxpayers, gifts of commodities to charitable organizations or family members have become an attractive way to reduce self-employment tax and, for noncharitable donees, to convert what would otherwise be ordinary income into capital gain. Although two private letter rulings, one issued in 1991 and one in 1992, disapproved the gifts of soybeans to the spouses, and have dampened enthusiasm for such transfers, gifts to other family members and to charitable organizations seem to be gaining in popularity.



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