Associated Milk Producers, Inc. v. Commissioner
United States Tax Court
1. For each of its taxable years 1959 through 1961, petitioner, a dairy cooperative, reported deductions in excess of gross income. Held: Petitioner entitled to net operating loss carryover deductions under sec. 172, I.R.C. 1954, in the succeeding years.
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1. For each of its taxable years 1959 through 1961, petitioner, a dairy cooperative, reported deductions in excess of gross income. Held: Petitioner entitled to net operating loss carryover deductions under sec. 172, I.R.C. 1954, in the succeeding years. Respondent's disallowance of net operating loss carryover, based upon "cost principle" of cooperative operation, rejected. 2. During each of its taxable years 1966 through 1968 petitioner made payments to reimburse operating deficits of a trust established to provide life insurance for member-patrons of petitioner. Held, under the…
1Opinion of the Court
Fay, Judge:
Respondent determined deficiencies in petitioner’s corporate income taxes as follows:
TYE Sept. 30— Deficiency TYE Sept. 30— Deficiency
1962. $59,638.33 1966. $13,187.01
1963. 54,963.19 1967. 9,600.12
1964. 115,043.14 1968. 19,362.00
1965. 15,083.79
Petitioner having conceded certain of the adjustments contained in the notice of deficiency, the issues remaining for our decision are as follows:(1) Whether petitioner, a dairy cooperative subject to the provisions of subchapter T (secs. 1381-1388),1 is entitled to offset its net income for the years 1962 through 1966 by the carryforward of…
2Cases cited11 opinions
- Snow v. CommissionerUnited States Tax Court · 1958
- Dinardo v. CommissionerUnited States Tax Court · 1954
- L. Heller & Son, Inc. v. CommissionerUnited States Tax Court · 1949
- Catholic News Publishing Co. v. CommissionerUnited States Tax Court · 1948
- Pomeroy Coop. Grain Co. v. CommissionerUnited States Tax Court · 1958
6 more not listed; retrieve them via the Exa API.
3Cited by20 opinions
- Farm Service Cooperative v. CommissionerUnited States Tax Court · 1978
- Farm Service Cooperative v. Commissioner of Internal Revenue, National Council of Farmer Cooperatives, AmicusCourt of Appeals for the Eighth Circuit · 1980
- Illinois Grain Corp. v. CommissionerUnited States Tax Court · 1986
- Buckeye Countrymark v. CommissionerUnited States Tax Court · 1994
- Certified Grocers of California, Ltd. v. CommissionerUnited States Tax Court · 1987
15 more not listed; retrieve them via the Exa API.