Legal Opinion

Seiners Asso. v. Commissioner

United States Tax Court

Decided September 20, 1972No. Docket No. 3212-71Published

Petitioner was a nonexempt cooperative which sold fishing gear, marine fuel, and insurance primarily to its members. In order to secure a deduction under sec. 1382(b), I.R.C. 1954, petitioner for the years ended Nov. 30, 1966, and Nov. 30, 1967, was required to make qualifying distributions of patronage dividends prior to Aug. 15, 1967, and Aug. 15, 1968, respectively.

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Petitioner was a nonexempt cooperative which sold fishing gear, marine fuel, and insurance primarily to its members. In order to secure a deduction under sec. 1382(b), I.R.C. 1954, petitioner for the years ended Nov. 30, 1966, and Nov. 30, 1967, was required to make qualifying distributions of patronage dividends prior to Aug. 15, 1967, and Aug. 15, 1968, respectively. Prior to the end of the required payment period, petitioner distributed to its members certain financial statements and receipts for goods purchased. These documents together could be used by the members to determine their…

1Opinion of the Court

Seiners Association, Petitioner v. Commissioner of Internal Revenue, Respondent

Seiners Asso. v. Commissioner

Docket No. 3212-71

United States Tax Court

58 T.C. 949; 1972 U.S. Tax Ct. LEXIS 60;

September 20, 1972, Filed

Decision will be entered for the respondent.

Petitioner was a nonexempt cooperative which sold fishing gear, marine fuel, and insurance primarily to its members. In order to secure a deduction under sec. 1382(b), I.R.C. 1954, petitioner for the years ended Nov. 30, 1966, and Nov. 30, 1967, was required to make qualifying distributions of patronage dividends prior to Aug. 15, 1967,…

2Cases cited17 opinions

  1. May v. HeinerSupreme Court of the United States · 1930
  2. Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
  3. Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
  4. Commissioner of Internal Revenue v. B. A. CarpenterCourt of Appeals for the Fifth Circuit · 1955
  5. McCamant v. CommissionerUnited States Tax Court · 1959

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