Legal Opinion

Alta Coop. Elevator v. Commissioner

United States Tax Court

Decided February 25, 1959No. Docket No. 65043Unpublished

1. Determination made as to the right of petitioner, a non-tax-exempt farmers' cooperative association, to exclude from its gross income as part of its patronage dividends, certain amounts allocated for the benefit of its members only, out of compensation received from the Commodity Credit Corporation (a government agency which was not a member of the petitioner cooperative) for handling and storing grain owned by such agency.

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1. Determination made as to the right of petitioner, a non-tax-exempt farmers' cooperative association, to exclude from its gross income as part of its patronage dividends, certain amounts allocated for the benefit of its members only, out of compensation received from the Commodity Credit Corporation (a government agency which was not a member of the petitioner cooperative) for handling and storing grain owned by such agency. Pomeroy Cooperative Grain Co., 31 T.C. - (Dec. 31, 1958), followed. 2. Held, that where petitioner kept its books and filed its Federal income tax returns on a calendar…

1Opinion of the Court

Alta Cooperative Elevator, a Corporation v. Commissioner.

Alta Coop. Elevator v. Commissioner

Docket No. 65043.

United States Tax Court

T.C. Memo 1959-33; 1959 Tax Ct. Memo LEXIS 213; 18 T.C.M. (CCH) 160; T.C.M. (RIA) 59033;

February 25, 1959

1. Determination made as to the right of petitioner, a non-tax-exempt farmers' cooperative association, to exclude from its gross income as part of its patronage dividends, certain amounts allocated for the benefit of its members only, out of compensation received from the Commodity Credit Corporation (a government agency which was not a member of the…

2Cases cited6 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Security Flour Mills Co. v. CommissionerSupreme Court of the United States · 1944
  3. Reynard Corp. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Booth Newspapers, Inc. v. CommissionerUnited States Tax Court · 1951
  5. Hygienic Products Co. v. CommissionerUnited States Board of Tax Appeals · 1938

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