FOUNTAIN CITY CO-OP. CR. ASS'N v. Commissioner of Int. Rev.

MINTON, Circuit Judge.

The Commissioner of Internal Revenue found and declared a deficiency in the income and declared value excess profits tax against the petitioner-taxpayer in the sum of $1,535.77. The Tax Court sustained the action of the Commissioner, and the taxpayer has appealed.

The taxpayer is a corporation of Wisconsin and claims to operate as a cooperative association under the laws of that state. It was engaged in the buying and selling of butter and in the buying and processing of butterfat. The taxpayer’s patrons consisted of producers of butterfat, of whom some were stockholders…