Legal Opinion

Illinois Grain Corp. v. Commissioner

United States Tax Court

Decided August 18, 1986No. Docket No. 6332-84Published

P, a nonexempt cooperative, derived certain income from interest on short-term loans and from barge rents, which R determined was income from nonpatronage sources within the meaning of subch. T, I.R.C. 1954. Under the facts, held, that the income was from patronage sources. St. Louis Bank for Cooperatives v. United States, 224 Ct. Cl. 289, 624 F.2d 1041 (1980), and Cotter & Co. v. United States, 765 F.2d 1102 (Fed. Cir. 1985), construed and followed.

1Opinion of the Court

Illinois Grain Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent

Illinois Grain Corp. v. Commissioner

Docket No. 6332-84

United States Tax Court

87 T.C. 435; 1986 U.S. Tax Ct. LEXIS 61; 87 T.C. No. 24;

August 18, 1986, Filed

Decision will be entered under Rule 155.

P, a nonexempt cooperative, derived certain income from interest on short-term loans and from barge rents, which R determined was income from nonpatronage sources within the meaning of subch. T, I.R.C. 1954. Under the facts, held, that the income was from patronage sources. St. Louis Bank for Cooperatives v. United…

2Cases cited10 opinions

  1. Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
  2. St. Louis Bank for Cooperatives v. United StatesUnited States Court of Claims · 1980
  3. Associated Milk Producers, Inc. v. CommissionerUnited States Tax Court · 1977
  4. Farm Service Cooperative v. CommissionerUnited States Tax Court · 1978
  5. Farm Service Cooperative v. Commissioner of Internal Revenue, National Council of Farmer Cooperatives, AmicusCourt of Appeals for the Eighth Circuit · 1980

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