Bloomberg Tax
Oct. 26, 2022, 8:45 AM

Saving a Farm From a High Tax Liability—Chris Hesse of CLA LLP

Chris Hesse
Chris Hesse
CliftonLarsonAllen LLP

When was the first moment that made you feel confident about your work as a tax pro?

I’m coming to the end of a 43-year career as a CPA. I had no idea that I would concentrate in tax, having graduated from a small state college in Oregon. My first job included all aspects of public accounting, including audited and unaudited financial statements, income, estate and gift taxes, and even profit-sharing plan allocations (before computers). I grew up in a farm family; agricultural tax became my specialty.

When the IRS proposed a $100,000 alternative minimum tax (AMT) liability on a farm client reporting $15,000 of regular taxable income, we took up the fight. The IRS asked if we wanted to pull back a technical advice memorandum (TAM) so that it wouldn’t be published. Farmers are very protective of deferred payment contracts as a tax planning device, and releasing the TAM would notify the farm community that the IRS would use the AMT to devastate a treasured planning opportunity for cash-basis farmers. A firestorm erupted that led to a 10-year retroactive repeal of IRC Section 56(a)(6), all from one examination of our client.

This article does not necessarily reflect the opinion of The Bureau of National Affairs, Inc., the publisher of Bloomberg Law and Bloomberg Tax, or its owners.

Author Information

Chris Hesse is principal in the national tax office of CliftonLarsonAllen LLP in Kennewick, Wash. and previously was director of taxation at LeMaster & Daniels PLLC in Spokane. He served as chairman of the AICPA Tax Executive Committee from 2019 to 2021.

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