Legal Opinion

Mississippi Chemical Corp. v. Commissioner

United States Tax Court

Decided April 9, 1986No. Docket Nos. 6556-82, 32440-83PublishedCited by 1 opinion

Upon the facts, held, that -- 1. Amounts paid by P, a nonexempt cooperative, resulting from purchases by SNS, SFA, and MFC, constituted patronage dividends deductible from its gross income pursuant to sec. 1382, I.R.C. 1954. 2. An amount paid by P, resulting from a purchase by PR, was neither deductible as a patronage dividend nor excludable as a purchase price refund. 3. "Dealer credits" granted by P to SNS were not ordinary or necessary business expenses within the meaning…

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Upon the facts, held, that -- 1. Amounts paid by P, a nonexempt cooperative, resulting from purchases by SNS, SFA, and MFC, constituted patronage dividends deductible from its gross income pursuant to sec. 1382, I.R.C. 1954. 2. An amount paid by P, resulting from a purchase by PR, was neither deductible as a patronage dividend nor excludable as a purchase price refund. 3. "Dealer credits" granted by P to SNS were not ordinary or necessary business expenses within the meaning of sec. 162.

1Opinion of the Court

KÓRNER, Judge:

Respondent determined deficiencies in Federal income tax against petitioner as follows:

Docket No. TYE June 30-Deficiency Additions to tax sec. 6653(a) 2

6556-82 1976 $4,042,534.95 $202,126.75

1977 4,351,882.91 217,594.15

32440-83 1978 383,128.30 0

1979 330,120.68 0

After concessions by both parties, the issues remaining for decision are (1) Whether, for the taxable years ending June 30, 1976, through June 30, 1979, certain amounts paid by petitioner, a nonexempt cooperative, constituted patronage dividends deductible from its gross income pursuant to section 1382; (2) whether, for…

2Cases cited17 opinions

  1. Welch v. HelveringSupreme Court of the United States · 1933
  2. Commissioner v. HeiningerSupreme Court of the United States · 1943
  3. Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
  4. Siegel v. CommissionerUnited States Tax Court · 1982
  5. Lilly v. CommissionerSupreme Court of the United States · 1952

12 more not listed; retrieve them via the Exa API.

3Cited by1 opinion

  1. Mississippi Chemical Corp. v. CommissionerUnited States Tax Court · 1986

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