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