Stevenson Co-Ply, Inc. v. Commissioner
United States Tax Court
Held, for the purpose of computing the alternative tax under sec. 1201(a), I.R.C. 1954, as amended, petitioner, a cooperative which produces and markets plywood and plywood byproducts, may reduce its sec. 631(a) gains by the amounts distributed to its stockholder employees as patronage dividends.
1Opinion of the Court
OPINION
Tietjens, Judge:
Respondent determined a deficiency of $255,028 in petitioner’s Federal income tax for 1973. The sole issue for decision is whether, for the purpose of computing the alternative tax under section 1201,1 a cooperative’s section 631(a) gains are excludable or deductible to the extent that the cooperative distributes those gains to its stockholders through patronage dividends.
This case was fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure. The stipulation of facts and attached exhibits are incorporated herein by reference.
At the time its…
2Cases cited24 opinions
- Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
- Union Equity Cooperative Exchange v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1973
- Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
- Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
- Walter M. Weil and Adele D. Weil v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1956
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3Cited by5 opinions
- Pesch v. CommissionerUnited States Tax Court · 1982
- Mississippi Chemical Corp. v. CommissionerUnited States Tax Court · 1986
- Mississippi Chemical Corp. v. CommissionerUnited States Tax Court · 1986
- Pesch v. CommissionerUnited States Tax Court · 1982
- Stevenson Co-Ply, Inc. v. CommissionerUnited States Tax Court · 1981