Legal Opinion

Farmers & Ginners Cotton Oil Co. v. Commissioner

United States Board of Tax Appeals

Decided February 6, 1940No. Docket No. 93436Published

Petitioner was engaged in the business of operating an independent cottonseed oil mill. Such operation consisted in buying and processing cottonseed and selling the products derived therefrom, namely, crude cottonseed oil, cottonseed meal, cotton linters, cottonseed hulls, cotton oil fibers, and bran. Crude cottonseed oil must be sold within a few weeks after production to avoid loss in value from deterioration in quality.

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Petitioner was engaged in the business of operating an independent cottonseed oil mill. Such operation consisted in buying and processing cottonseed and selling the products derived therefrom, namely, crude cottonseed oil, cottonseed meal, cotton linters, cottonseed hulls, cotton oil fibers, and bran. Crude cottonseed oil must be sold within a few weeks after production to avoid loss in value from deterioration in quality. Beyond such period it can not be withheld from sale to await an advantageous market. Because of such market hazard it is the general practice of the operators of such mills…

1Opinion of the Court

FARMERS & GINNERS COTTON OIL COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Farmers & Ginners Cotton Oil Co. v. Commissioner

Docket No. 93436.

United States Board of Tax Appeals

41 B.T.A. 255; 1940 BTA LEXIS 1205;

February 6, 1940, Promulgated

Petitioner was engaged in the business of operating an independent cottonseed oil mill. Such operation consisted in buying and processing cottonseed and selling the products derived therefrom, namely, crude cottonseed oil, cottonseed meal, cotton linters, cottonseed hulls, cotton oil fibers, and bran. Crude cottonseed oil must be sold…

2Cases cited8 opinions

  1. Marengo Abstract Co. v. Hooper & Co.Supreme Court of Alabama · 1911
  2. Adirondack Sec. Corp. v. CommissionerUnited States Board of Tax Appeals · 1931
  3. Oil Shares, Inc. v. CommissionerUnited States Board of Tax Appeals · 1934
  4. Farmers & Ginners Cotton Oil Co. v. CommissionerUnited States Board of Tax Appeals · 1940
  5. Shannon v. McClungSupreme Court of Alabama · 1923

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