Growers Credit Corp. v. Commissioner
United States Tax Court
1. Corporation organized to finance crop operations of members and other fruit producers in area, held, not exempt under section 101(13), I.R.C. 1939. 2. Deposits of 5 cents per box of fruit sold by borrower-stockholders to indemnify lending corporation against credit and operating losses, held, not taxable income to corporation in year of receipt.
1Opinion of the Court
Drennen, Judge:
Respondent determined deficiencies in petitioner’s income taxes and a 5 per cent negligence addition to tax under section 293(a), I.R.C. 1939, as follows:
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The issues for decision are whether petitioner is exempt from tax under section 101(13), I.R.C. 1939, and if not, whether deposits of 5 cents per box of fruit sold by its borrower-stockholders required under terms of the loan agreement to indemnify petitioner against credit and operating losses are taxable income to petitioner in the year of receipt. It becomes unnecessary for us to pass on other issues raised in…
2Cases cited21 opinions
- Eisner v. MacOmberSupreme Court of the United States · 1920
- North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
- Luckenbach v. W. J. McCahan Sugar Refining Co.Supreme Court of the United States · 1918
- Heiner v. Colonial Trust Co.Supreme Court of the United States · 1927
- Automobile Club of New York, Inc. v. CommissionerUnited States Tax Court · 1959
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3Cited by8 opinions
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- Concord Village, Inc. v. CommissionerUnited States Tax Court · 1975
- Colonial Wholesale Beverage Corp. v. CommissionerUnited States Tax Court · 1988
- Schochet v. CommissionerUnited States Tax Court · 1982
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