Farmers & Ginners Cotton Oil Co. v. Commissioner
United States Board of Tax Appeals
Petitioner was engaged in the business of operating an independent cottonseed oil mill. Such operation consisted in buying and processing cottonseed and selling the products derived therefrom, namely, crude cottonseed oil, cottonseed meal, cotton linters, cottonseed hulls, cotton oil fibers, and bran. Crude cottonseed oil must be sold within a few weeks after production to avoid loss in value from deterioration in quality.
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Petitioner was engaged in the business of operating an independent cottonseed oil mill. Such operation consisted in buying and processing cottonseed and selling the products derived therefrom, namely, crude cottonseed oil, cottonseed meal, cotton linters, cottonseed hulls, cotton oil fibers, and bran. Crude cottonseed oil must be sold within a few weeks after production to avoid loss in value from deterioration in quality. Beyond such period it can not be withheld from sale to await an advantageous market. Because of such market hazard it is the general practice of the operators of such mills…
1Opinion of the Court
*259OPINION.
Hill:
The petitioner contends that the losses it sustained in its dealings in refined oil futures were normal business losses. This *260claim is based primarily upon the broad hypothesis that the initial processing of raw cottonseed is so related to the manufacture of refined cottonseed oil as to make stocks of the latter product invoiceable 'as regular “stock in trade” of the processor. Secondarily, the petitioner contends that, in any event, its dealings in oil futures were transactions entered into for profit and that the resulting losses are deductible under section 23 (f) of the…
2Cases cited3 opinions
- Marengo Abstract Co. v. Hooper & Co.Supreme Court of Alabama · 1911
- Shannon v. McClungSupreme Court of Alabama · 1923
- Smith v. OdellAlabama Court of Appeals · 1926
3Cited by8 opinions
- Federal Nat'l Mortgage Ass'n v. CommissionerUnited States Tax Court · 1993
- Vickers v. CommissionerUnited States Tax Court · 1983
- Buehler v. CommissionerUnited States Tax Court · 1987
- Trenton Cotton Oil Co. v. CommissionerUnited States Tax Court · 1943
- Farmers & Ginners Cotton Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1940
3 more not listed; retrieve them via the Exa API.