California & Hawaiian Sugar Refining Corp. v. Commissioner of Internal Revenue

DENMAN, Circuit Judge.

Petitioner is a so-called California cooperative marketing association organized under the California Agricultural Code, hereinafter called the cooperative. The members of the cooperative are thirty producers of ■ raw sugar in the Hawaiian Islands, who transferred title of their sugar to the cooperative for processing and sale under a contract hereafter considered. The contract was made long before the enactment of the processing tax here considered and the case presents no question of tax avoidance.

The cooperative seeks a review of decisions of the Tax Court granting…