Legal Opinion

CF Industries, Inc. v. Commissioner

Court of Appeals for the Seventh Circuit

Decided May 26, 1993No. Nos. 92-1579, 92-2046PublishedCited by 1 opinion

1Opinion of the Court

POSNER, Circuit Judge.

The principal difference between the cooperative form of doing business and the ordinary corporate form is that the shareholders of a cooperative share in the cooperative’s income in proportion to their purchases from the cooperative rather than to the number of shares they own. Subchapter T of the Internal Revenue Code, 26 U.S.C. §§ 1381-1388, sets forth special rules for the taxation of cooperatives. The rules differ depending on whether the cooperative is an “exempt” coop*102erative or a “nonexempt” one, but we are concerned in this case only with the latter. The…

2Cases cited10 opinions

  1. St. Louis Bank for Cooperatives v. United StatesUnited States Court of Claims · 1980
  2. Conway County Farmers Association v. United StatesCourt of Appeals for the Eighth Circuit · 1978
  3. Illinois Grain Corp. v. CommissionerUnited States Tax Court · 1986
  4. Land O'lakes, Inc., Formerly Land O'Lakes Creameries, Inc., a Minnesota Corporation v. United StatesCourt of Appeals for the Eighth Circuit · 1982
  5. Cotter and Company and Subsidiaries v. The United StatesCourt of Appeals for the Federal Circuit · 1985

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3Cited by1 opinion

  1. Cf Industries, Inc. v. Commissioner Of Internal RevenueCourt of Appeals for the Seventh Circuit · 1993

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