Gold Kist v. Commissioner
United States Tax Court
P, a taxable farmers cooperative, distributed patronage dividends to its patrons annually in accordance with its bylaws. Some of the patronage dividends were issued as qualified written notices of allocation as defined in sec. 1388(c)(1), I.R.C. Patrons included the stated amounts of the qualified written notices of allocation in their gross income. P deducted the stated amounts of the qualified written notices of allocation under sec. 1382(b), I.R.C.
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P, a taxable farmers cooperative, distributed patronage dividends to its patrons annually in accordance with its bylaws. Some of the patronage dividends were issued as qualified written notices of allocation as defined in sec. 1388(c)(1), I.R.C. Patrons included the stated amounts of the qualified written notices of allocation in their gross income. P deducted the stated amounts of the qualified written notices of allocation under sec. 1382(b), I.R.C. P adopted a policy of redeeming terminating patrons' qualified written notices of allocation upon written demand. In a redemption, P pays cash…
1Opinion of the Court
Wells, Judge:
Respondent determined the following deficiencies in petitioner’s Federal income taxes:
Deficiency TYE
$1,107,667 June 30, 1987
1,150,964 June 30, 1988
840,866 June 30, 1989
Unless otherwise indicated, all subchapter and section references are to the Internal Revenue Code in effect for the taxable years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.
After concessions,1 the issues for decision are (1) whether the tax benefit rule requires petitioner to recognize income upon the redemption of “qualified written notices of allocation” at less than…
2Cases cited19 opinions
- Corn Products Refining Co. v. CommissionerSupreme Court of the United States · 1956
- Humes v. United StatesSupreme Court of the United States · 1928
- Hillsboro National Bank v. CommissionerSupreme Court of the United States · 1983
- Arkansas Best Corp. v. CommissionerSupreme Court of the United States · 1988
- Segel v. CommissionerUnited States Tax Court · 1987
14 more not listed; retrieve them via the Exa API.
3Cited by3 opinions
- Gold Kist, Inc. v. Comr. of IRSCourt of Appeals for the Eleventh Circuit · 1997
- AFFILIATED FOODS, INC. v. COMMISSIONERUnited States Tax Court · 1996
- Gold Kist v. CommissionerUnited States Tax Court · 1995