Joplin v. Commissioner
United States Tax Court
Petitioners William A. Joplin, Jr., Joseph F. Kohn and S. Crews Reynolds were members of a tax exempt farmers' marketing cooperative corporation, reporting their income on the cash receipts and disbursements basis of accounting.
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Petitioners William A. Joplin, Jr., Joseph F. Kohn and S. Crews Reynolds were members of a tax exempt farmers' marketing cooperative corporation, reporting their income on the cash receipts and disbursements basis of accounting. In the taxable years involved, the net earnings of the cooperative were allocated and distributed to its members in the form of credits to its capital reserve account and the issuance of certificates of its preferred stock having a par value of $ 25 per share. Held, petitioners received and realized income upon the receipt of the certificates of preferred stock to the…
1Opinion of the Court
OPINION.
LeMieb, Judge:
The question presented is whether income was realized by the taxpayers, in the respective taxable years involved, upon the allocation and distribution of the net savings or earnings of the Osceola Products Company to the petitioners who were members of the association, in the form of credits to its capital reserve account and the issuance of preferred stock of such corporation.
The petitioners, William A. Joplin, Jr., Joseph F. Kohn, and S. Crews Reynolds, were members of the Osceola Products Company, a nonprofit cooperative corporation exempt from tax under the…
2Cases cited3 opinions
- Harbor Plywood Corp. v. CommissionerUnited States Tax Court · 1950
- Colony Farms Cooperative Dairy, Inc. v. CommissionerUnited States Tax Court · 1951
- Caswell v. CommissionerUnited States Tax Court · 1952
3Cited by2 opinions
- Coastal Chemical Corporation v. United StatesCourt of Appeals for the Fifth Circuit · 1977
- Joplin v. CommissionerUnited States Tax Court · 1952