Concord Consumers Hous. Coop. v. Commissioner
United States Tax Court
P is a federally subsidized, nonexempt, nonprofit corporation organized to provide housing for persons of low and moderate incomes.
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P is a federally subsidized, nonexempt, nonprofit corporation organized to provide housing for persons of low and moderate incomes. P earned interest income on two reserve accounts and on an escrow account it was required to maintain under its agreements with the Federal Housing Administration (FHA) and the Michigan State Housing Development Authority (MSHDA). Held, interest income earned on those accounts is not "income derived * * * from members or transactions with members" within the meaning of sec. 277(a), I.R.C. 1954, and constitutes nonmembership income. Held, further, expenses…
1Opinion of the Court
Concord Consumers Housing Cooperative, Petitioner v. Commissioner of Internal Revenue, Respondent
Concord Consumers Hous. Coop. v. Commissioner
Docket No. 31365-81
United States Tax Court
89 T.C. 105; 1987 U.S. Tax Ct. LEXIS 101; 89 T.C. No. 12;
July 16, 1987July 16, 1987, Filed
Decision will be entered under Rule 155.
P is a federally subsidized, nonexempt, nonprofit corporation organized to provide housing for persons of low and moderate incomes. P earned interest income on two reserve accounts and on an escrow account it was required to maintain under its agreements with the Federal Housing…
Also in this document: Concurrence.
2Cases cited22 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- United States v. American Trucking AssociationsSupreme Court of the United States · 1940
- United States v. American Bar EndowmentSupreme Court of the United States · 1986
- United States v. American College of PhysiciansSupreme Court of the United States · 1986
- Graff v. CommissionerUnited States Tax Court · 1980
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