qualified farming trade or business
(4) Qualified partnership defined For purposes of this subsection— (A) Qualified partnership The term “qualified partnership” means a partnership which is engaged in a qualified farming trade or business and each of the partners of which is a corporation other than— (i) an S corporation, or (ii) a personal holding company (within the meaning of section 542(a) ). (B) Qualified farming trade or business (i) In general The term “qualified farming trade or business” means the trade or business of farming— (I) sugar cane, (II) any plant with a preproductive period (as defined in section 263A(e)(3)) of 2 years or less, and (III) any other plant (other than any citrus or almond tree) if an election by the corporation under this subparagraph is in effect. In the case of a partnership and for purposes of paragraph (3)(A), subclauses (II) and (III) shall not apply. (ii) Effect of election For purposes of paragraphs (1) and (2) of section 263A(e), any election under this subparagraph shall be treated as if it were an election under subsection (d)(3) of section 263A. (iii) Election Unless the Secretary otherwise consents, an election under this subparagraph may be made only for the corporation’s 1st taxable year which begins after December 31, 1986 , and during which the corporation engages in a farming business. Any such election, once made, may be revoked only with the consent of the Secretary.