Legal Opinion

Farmers Union State Exchange v. Commissioner

United States Board of Tax Appeals

Decided June 28, 1934No. Docket Nos. 10596, 18105, 27194, 31748PublishedCited by 5 opinions

1. The Farmers Educational and Cooperative State Union of Nebraska, a cooperative organization under the laws of Nebraska, having no capital stock; its members being members of local cooperative groups who, except for a negligible number, were working farmers; its income being principally from fees and dues of its members; its purposes being to instruct and educate the agricultural classes in scientific farming, classification of crops, domestic economy, and processes of…

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1. The Farmers Educational and Cooperative State Union of Nebraska, a cooperative organization under the laws of Nebraska, having no capital stock; its members being members of local cooperative groups who, except for a negligible number, were working farmers; its income being principally from fees and dues of its members; its purposes being to instruct and educate the agricultural classes in scientific farming, classification of crops, domestic economy, and processes of marketing, to systematize the methods of production and distribution, and to assist its members in cooperative buying and…

1Opinion of the Court

*1062OPINION.

Matthews :

The main issues for determination are (1) whether the Farmers Educational and Cooperative State. Union of Nebraska is an exempt corporation under the provisions of the Revenue Acts of 1916, 1918, and 1921; (2) whether the Farmers Union State Exchange is an exempt corporation under the provisions of the Revenue Acts of 1916 and 1918, and, if not, (3) whether it is taxable on the undistributed savings of 1917 and 1918; and (4) whether the period of limitation for 1918 had expired prior to the date on which the notice of deficiency for that year was mailed.

If the State Union is…

2Cases cited2 opinions

  1. Farmers' Union Co-Op. Ass'n v. CommissionerUnited States Board of Tax Appeals · 1928
  2. Ethel D. Co. v. CommissionerUnited States Board of Tax Appeals · 1932

3Cited by5 opinions

  1. Farmers Cooperative Co. v. BirminghamDistrict Court, N.D. Iowa · 1949
  2. Estate of Camara v. CommissionerUnited States Tax Court · 1988
  3. Simmons v. WestoverDistrict Court, S.D. California · 1948
  4. Estate of Camara v. CommissionerUnited States Tax Court · 1988
  5. Farmers Union State Exchange v. CommissionerUnited States Board of Tax Appeals · 1934

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