Legal Opinion

Stevenson Co-Ply, Inc. v. Commissioner

United States Tax Court

Decided April 23, 1981No. Docket No. 8659-79Published

Held, for the purpose of computing the alternative tax under sec. 1201(a), I.R.C. 1954, as amended, petitioner, a cooperative which produces and markets plywood and plywood byproducts, may reduce its sec. 631(a) gains by the amounts distributed to its stockholder employees as patronage dividends.

1Opinion of the Court

Stevenson Co-Ply, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent

Stevenson Co-Ply, Inc. v. Commissioner

Docket No. 8659-79

United States Tax Court

76 T.C. 637; 1981 U.S. Tax Ct. LEXIS 139;

April 23, 1981, Filed

Decision will be entered under Rule 155.

Held, for the purpose of computing the alternative tax under sec. 1201(a), I.R.C. 1954, as amended, petitioner, a cooperative which produces and markets plywood and plywood byproducts, may reduce its sec. 631(a) gains by the amounts distributed to its stockholder employees as patronage dividends.

Wesley W. Kirtley, for the petitioner.

Le…

2Cases cited26 opinions

  1. Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
  2. Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
  3. Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
  4. Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
  5. Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956

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