Caldwell Sugars Co-op., Inc. v. United States

OPINION

ARCENEAUX, District Judge.

This matter comes to the Court on a set of facts to which both parties have stipulated. The essence of those facts is stated below.

FACTS

Caldwell Sugars Co-op., Inc. (“Caldwell”) is a classic kind of corporate structure known as a cooperative; its members are producers of sugarcane who have joined together, as the law both permits and encourages, to manufacture, process, handle, market, buy, sell, and ship sugarcane and sugarcane products for their mutual benefit. As a nonexempt farmers’ cooperative corporation, Caldwell’s taxable income for its taxable year…