Since it was enacted in 1969,1 the provision authorizing a one-year deferral to the year after the year of “destruction or damage to crops”2 has drawn very little attention. Other than Treasury Regulations,3 a 1974 revenue ruling4 a notice issued in 19895 and assorted other (mostly minor) rulings,6 the subsection, which has been important to many farmers, has provoked little scrutiny by the Internal Revenue Service and has not been litigated.