Legal Opinion
Farm Service Cooperative v. Commissioner of Internal Revenue, National Council of Farmer Cooperatives, Amicus
Court of Appeals for the Eighth Circuit
Decided May 19, 1980No. 78-1754PublishedCited by 20 opinions
1Opinion of the Court
BRIGHT, Circuit Judge.
The Commissioner of Internal Revenue (Commissioner) appeals from a decision of the United States Tax Court in favor of Farm Service Cooperative (taxpayer). 1 The Tax Court determined that taxpayer, a nonexempt farm cooperative, 2 could offset losses suffered in patronage activities against its taxable income. For the reasons set forth below, we conclude that this determination was erroneous. Accordingly, We reverse.
1. Background.
Taxpayer is an agricultural cooperative incorporated under the laws of Arkansas, with its principal place of business in Fa-yetteville. During…
2Cases cited15 opinions
- Hormel v. HelveringSupreme Court of the United States · 1941
- Thor Power Tool Co. v. CommissionerSupreme Court of the United States · 1979
- Arrowsmith v. CommissionerSupreme Court of the United States · 1952
- Don E. Williams Co. v. CommissionerSupreme Court of the United States · 1977
- Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
10 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Concord Consumers Hous. Coop. v. CommissionerUnited States Tax Court · 1987
- Illinois Grain Corp. v. CommissionerUnited States Tax Court · 1986
- Buckeye Countrymark v. CommissionerUnited States Tax Court · 1994
- St. James Sugar Cooperative, Inc., Cross v. United States of America, CrossCourt of Appeals for the Fifth Circuit · 1981
- Certified Grocers of California, Ltd. v. CommissionerUnited States Tax Court · 1987
15 more not listed; retrieve them via the Exa API.