Consumers Credit Rural Electric Cooperative Corp. v. Commissioner
United States Tax Court
Petitioner was organized by a number of rural electric cooperative associations for the purpose of having it finance purchases of home appliances, electric wiring systems, and the like, by the patrons of the electric cooperative associations. Petitioner derived its operating capital by bank loans and sale of debentures to its member electric cooperative associations.
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Petitioner was organized by a number of rural electric cooperative associations for the purpose of having it finance purchases of home appliances, electric wiring systems, and the like, by the patrons of the electric cooperative associations. Petitioner derived its operating capital by bank loans and sale of debentures to its member electric cooperative associations. Held, petitioner is not an exempt organization under section 501(c)(12) of the Internal Revenue Code of 1954. Held, further, the debentures represented an equity interest in petitioner and payments thereon in 1957 were not…
1Opinion of the Court
MulRonet, Judge:
The respondent determined a deficiency in petitioner’s income tax for the year 1957 in the amount of $2,779.58 and in his amended answer respondent claims an additional deficiency of $1,478.41 in petitioner’s income tax for 1957. The issues are (1) whether petitioner is a tax-exempt organization within the meaning of section 501(c) (12) ; (2) whether certain distributions paid by petitioner to holders of its purported debentures are deductible as interest payments under section 163; and (3) whether petitioner is entitled to a deduction of $3,052.44 claimed by it in 1956 for…
2Cases cited16 opinions
- Gooding Amusement Co. v. CommissionerUnited States Tax Court · 1954
- United States v. Magnolia Petroleum Co.Supreme Court of the United States · 1928
- Dobkin v. CommissionerUnited States Tax Court · 1950
- Underwriters' Laboratories, Inc. v. CommissionerCourt of Appeals for the Seventh Circuit · 1943
- Wilbur Sec. Co. v. CommissionerUnited States Tax Court · 1959
11 more not listed; retrieve them via the Exa API.
3Cited by8 opinions
- Atwood Grain & Supply Co. v. CommissionerUnited States Tax Court · 1973
- Grange Ins. Asso. v. CommissionerUnited States Tax Court · 1961
- Consumers Credit Rural Electric Cooperative Corp. v. CommissionerUnited States Tax Court · 1964
- FCX, Inc. v. United StatesUnited States Court of Claims · 1976
- Atwood Grain & Supply Co. v. CommissionerUnited States Tax Court · 1973
3 more not listed; retrieve them via the Exa API.