Legal Opinion

Farmers Cooperative Co. v. Commissioner

United States Tax Court

Decided November 17, 1959No. Docket No. 68952Published

1. Held, exclusions claimed by petitioner, a nonexempt farmers' cooperative, for patronage refunds disallowed since its refundable earnings were not properly allocated pursuant to the provisions in the respondent's regulations. Regs. 118, sec. 39.101(12)-2(b)(3); Income Tax Regs., sec. 1.522-1(b)(3). 2. Held, petitioner failed to make a timely election under section 169(b), I.R.C. 1954, to amortize a grain storage facility completed in June 1954.

1Opinion of the Court

Farmers Cooperative Company, Petitioner, v. Commissioner of Internal Revenue, Respondent

Farmers Cooperative Co. v. Commissioner

Docket No. 68952

United States Tax Court

33 T.C. 266; 1959 U.S. Tax Ct. LEXIS 40;

November 17, 1959, Filed

Decision will be entered under Rule 50.

1. Held, exclusions claimed by petitioner, a nonexempt farmers' cooperative, for patronage refunds disallowed since its refundable earnings were not properly allocated pursuant to the provisions in the respondent's regulations. Regs. 118, sec. 39.101(12)-2(b)(3); Income Tax Regs., sec. 1.522-1(b)(3).

2. Held, petitioner failed to…

2Cases cited11 opinions

  1. United States v. AndersonSupreme Court of the United States · 1926
  2. Manhattan General Equipment Co. v. Commissioner of Internal RevenueSupreme Court of the United States · 1936
  3. Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
  4. Pomeroy Coop. Grain Co. v. CommissionerUnited States Tax Court · 1958
  5. Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957

6 more not listed; retrieve them via the Exa API.

Showing a preview — retrieve the full document via the Exa API.

Powered by the Exa API