Independent Cooperative Milk Producers Asso. v. Commissioner
United States Tax Court
Petitioner, a farmers' cooperative, amended its bylaws in 1967 so as to comply with sec. 1388(c)(2)(B)(i), I.R.C. 1954. Petitioner's membership was notified of this change in 1967. The membership agreement signed by petitioner's post-1967 members provides that each member agrees "to abide by all rules and regulations." Petitioner did not distribute copies of its bylaws as amended to its post-1967 members.
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Petitioner, a farmers' cooperative, amended its bylaws in 1967 so as to comply with sec. 1388(c)(2)(B)(i), I.R.C. 1954. Petitioner's membership was notified of this change in 1967. The membership agreement signed by petitioner's post-1967 members provides that each member agrees "to abide by all rules and regulations." Petitioner did not distribute copies of its bylaws as amended to its post-1967 members. In accordance with its bylaws, petitioner allocates its net annual earnings to its members by means of patronage dividends. During the years in issue, petitioner paid 20 percent of its…
1Opinion of the Court
Independent Cooperative Milk Producers Association, Inc., Petitioner v. Commissioner of Internal Revenue, Respondent
Independent Cooperative Milk Producers Asso. v. Commissioner
Docket No. 10791-78
United States Tax Court
76 T.C. 1001; 1981 U.S. Tax Ct. LEXIS 111;
June 15, 1981, Filed
Decision will be entered for the respondent.
Petitioner, a farmers' cooperative, amended its bylaws in 1967 so as to comply with sec. 1388(c)(2)(B)(i), I.R.C. 1954. Petitioner's membership was notified of this change in 1967. The membership agreement signed by petitioner's post-1967 members provides that each member…
2Cases cited8 opinions
- Commissioner v. South Texas Lumber Co.Supreme Court of the United States · 1948
- 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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