Legal Opinion

Farmers Coop. Co. v. Commissioner

United States Tax Court

Decided September 29, 1987No. Docket No. 15643-82Published

P, a farmers cooperative association, sought to qualify as an exempt cooperative association under sec. 521, I.R.C. 1954. R, by means of a revenue ruling, set an 85-percent patronage requirement by active capital stockholder, which standard was approved by the Eighth Circuit and this Court.

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P, a farmers cooperative association, sought to qualify as an exempt cooperative association under sec. 521, I.R.C. 1954. R, by means of a revenue ruling, set an 85-percent patronage requirement by active capital stockholder, which standard was approved by the Eighth Circuit and this Court. R, by means of a revenue procedure, attempted to set a 50-percent patronage requirement for each patron who was a capital stockholder and considered to meet the 85-percent test of the revenue ruling. Held: For purposes of sec. 521, I.R.C. 1954, any amount of patronage will be sufficient for a patron to be…

1Opinion of the Court

Farmers Cooperative Company (Sucessor-in-Name to Farmers Co-Op Oil Company), Petitioner v. Commissioner of Internal Revenue, Respondent

Farmers Coop. Co. v. Commissioner

Docket No. 15643-82

United States Tax Court

89 T.C. 682; 1987 U.S. Tax Ct. LEXIS 137; 89 T.C. No. 47;

September 29, 1987; As amended October 1, 1987 September 29, 1987, Filed

Decision will be entered under Rule 155.

P, a farmers cooperative association, sought to qualify as an exempt cooperative association under sec. 521, I.R.C. 1954. R, by means of a revenue ruling, set an 85-percent patronage requirement by active capital…

2Cases cited6 opinions

  1. Bingham v. United StatesSupreme Court of the United States · 1935
  2. Co-Operative Grain & Supply Co. v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1969
  3. West Central Cooperative v. United StatesCourt of Appeals for the Eighth Circuit · 1985
  4. Farmers Cooperative Co. v. CommissionerUnited States Tax Court · 1985
  5. Farmers Coop. Co. v. CommissionerUnited States Tax Court · 1987

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