Ford-Iroquois FS, Inc. v. Commissioner
United States Tax Court
Petitioner, a nonexempt agricultural cooperative, operates both a grain department and an agricultural supply department. The grain department performs selling and storage functions while the supply department sells petroleum, fertilizer, feed, and other products. Both departments do business with cooperative members and nonmembers.
Read the full summary
Petitioner, a nonexempt agricultural cooperative, operates both a grain department and an agricultural supply department. The grain department performs selling and storage functions while the supply department sells petroleum, fertilizer, feed, and other products. Both departments do business with cooperative members and nonmembers. During two "short periods" in 1971 and the calendar year 1972, petitioner and Ford County FS, Inc. (which merged into petitioner on Jan. 31, 1971), reported net operating losses. The board of directors and managers of petitioner elected to carry forward and offset…
1Opinion of the Court
Dawson, Judge:
Respondent determined a deficiency of $160,313 in petitioner’s Federal income tax for the year 1973.
Certain adjustments have been conceded by both petitioner and respondent. The issues for decision are: (1) Whether petitioner, a nonexempt cooperative, may carry forward under section 1721 losses incurred in its grain marketing and storage operations to offset income from its farm supply operations, and (2) whether it may carry forward losses incurred in the grain and supply operations arising out of transactions with cooperative members who terminated their membership after the…
2Cases cited13 opinions
- Frost v. Corporation Comm'n of Okla.Supreme Court of the United States · 1929
- Burk-Waggoner Oil Assn. v. HopkinsSupreme Court of the United States · 1925
- Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
- United States v. Mississippi Chemical CompanyCourt of Appeals for the Fifth Circuit · 1964
8 more not listed; retrieve them via the Exa API.
3Cited by10 opinions
- Buckeye Countrymark v. CommissionerUnited States Tax Court · 1994
- Certified Grocers of California, Ltd. v. CommissionerUnited States Tax Court · 1987
- Buckeye Power, Inc. v. United StatesUnited States Court of Federal Claims · 1997
- Lamesa Cooperative Gin v. CommissionerUnited States Tax Court · 1982
- Kingfisher Cooperative Elevator Asso. v. CommissionerUnited States Tax Court · 1985
5 more not listed; retrieve them via the Exa API.