Cal-Maine Foods, Inc. v. Commissioner
United States Tax Court
"Farms" and "Dairy Fresh," wholly owned subsidiaries of P, are farming corporations. Before and for the year in issue, "Farms" and "Dairy Fresh" used the cash receipts and disbursements method of accounting for tax purposes.
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"Farms" and "Dairy Fresh," wholly owned subsidiaries of P, are farming corporations. Before and for the year in issue, "Farms" and "Dairy Fresh" used the cash receipts and disbursements method of accounting for tax purposes. Pursuant to sec. 447(a) of the Internal Revenue Code of 1954, effective for the first taxable year beginning after Dec. 31, 1976, "Farms" and "Dairy Fresh" were required to change to the accrual method of accounting unless one of the specific exceptions to sec. 447(a) applied. In order to satisfy the "family corporation" exception to sec. 447(a), P arranged, through…
1Opinion of the Court
Cal-Maine Foods, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Cal-Maine Foods, Inc. v. Commissioner
Docket No. 22144-84
United States Tax Court
93 T.C. 181; 1989 U.S. Tax Ct. LEXIS 115; 93 T.C. No. 19;
August 8, 1989; As corrected September 8, 1989 August 8, 1989, Filed
Decision will be entered under Rule 155.
"Farms" and "Dairy Fresh," wholly owned subsidiaries of P, are farming corporations. Before and for the year in issue, "Farms" and "Dairy Fresh" used the cash receipts and disbursements method of accounting for tax purposes. Pursuant to sec. 447(a) of the Internal Revenue…
2Cases cited48 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Corliss v. BowersSupreme Court of the United States · 1930
- Aaron v. Securities & Exchange CommissionSupreme Court of the United States · 1980
- United States v. Cumberland Public Service Co.Supreme Court of the United States · 1950
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