Farmers Cooperative Co. v. Commissioner
United States Tax Court
Petitioners were tax-exempt farmers' cooperatives that had been granted exempt status in 1929 and 1956. Each petitioner was audited for 2 years during the period 1977 through 1980. Respondent determined that both petitioners failed to meet the requirement of sec. 521, I.R.C. 1954, that substantially all of the capital stock be owned by producers who market products or purchase supplies and equipment through the cooperatives.
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Petitioners were tax-exempt farmers' cooperatives that had been granted exempt status in 1929 and 1956. Each petitioner was audited for 2 years during the period 1977 through 1980. Respondent determined that both petitioners failed to meet the requirement of sec. 521, I.R.C. 1954, that substantially all of the capital stock be owned by producers who market products or purchase supplies and equipment through the cooperatives. Respondent's determination to revoke tax-exempt status was predicated upon an 85-percent minimum threshold for the "substantially all" requirement of sec. 521(b)(2),…
1Opinion of the Court
Farmers Cooperative Company (Successor-in-Name to Farmers Co-Op Oil Company), Petitioner v. Commissioner of Internal Revenue, Respondent; Farmers Cooperative Society, Petitioner v. Commissioner of Internal Revenue, Respondent
Farmers Cooperative Co. v. Commissioner
Docket Nos. 15643-82, 5988-83
United States Tax Court
85 T.C. 601; 1985 U.S. Tax Ct. LEXIS 28; 85 T.C. No. 36;
October 24, 1985, Filed
Decisions will be entered under Rule 155.
Petitioners were tax-exempt farmers' cooperatives that had been granted exempt status in 1929 and 1956. Each petitioner was audited for 2 years during the period…
Also in this document: Dissent.
2Cases cited20 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- United States v. CorrellSupreme Court of the United States · 1967
- Helvering v. WinmillSupreme Court of the United States · 1938
- Helvering v. Northwest Steel Rolling Mills, Inc.Supreme Court of the United States · 1940
- Tank Truck Rentals, Inc. v. CommissionerSupreme Court of the United States · 1958
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