Garnac Grain Co. v. Commissioner
United States Tax Court
G was a worldwide grain merchant whose business consisted primarily of purchasing grain (soybeans, corn, and wheat); cleaning, drying, aerating, fumigating, and blending this grain; and then selling it for export to customers in 40 to 50 countries throughout the world. G owned all of the issued and outstanding shares of E, a Domestic International Sales Corporation (DISC). During May 1974, E made loans to G totaling $ 5.4 million.
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G was a worldwide grain merchant whose business consisted primarily of purchasing grain (soybeans, corn, and wheat); cleaning, drying, aerating, fumigating, and blending this grain; and then selling it for export to customers in 40 to 50 countries throughout the world. G owned all of the issued and outstanding shares of E, a Domestic International Sales Corporation (DISC). During May 1974, E made loans to G totaling $ 5.4 million. Held, G was not engaged in the production or growing of export property within the meaning of sec. 993(d)(1)(C), I.R.C., and, therefore, the loans by E to G did not…
1Opinion of the Court
COHEN, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes as follows:
Docket No. Petitioner Year Deficiency
35832-85 Garnac Grain Co. 1974 $4,323,538
1975 940,401
1976 1,234,496
8213-86 Garnac Grain Export 1974 5,188,318
1975 3,231,062
1976 2,922,375
7840-87 Garnac Grain Co. 1978 72,959
1979 147,050
1981 1107,904
7848-87 Garnac Grain Co., 1977 423,579
Transferee 1978 431,994
1979 489,178
Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the years in issue.
After concessions, the issue remaining for decision is whether…
2Cases cited15 opinions
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