Illinois Grain Corp. v. Commissioner
United States Tax Court
P, a nonexempt cooperative, derived certain income from interest on short-term loans and from barge rents, which R determined was income from nonpatronage sources within the meaning of subch. T, I.R.C. 1954. Under the facts, held, that the income was from patronage sources. St. Louis Bank for Cooperatives v. United States, 224 Ct. Cl. 289, 624 F.2d 1041 (1980), and Cotter & Co. v. United States, 765 F.2d 1102 (Fed. Cir. 1985), construed and followed.
1Opinion of the Court
KÓRNER, Judge:
For the short fiscal period June 1, 1979, through February 29, 1980, respondent determined a deficiency of $1,595,926 of corporate income tax against petitioner. After concessions by both sides, the issues which we must determine are (a) whether certain income earned by petitioner in the taxable period constituted income from patronage sources within the meaning of subchapter T,1 and (b) if not, whether such income is subject to reduction by any offsetting expenses attributable thereto in amounts in excess of those allowed by respondent.
FINDINGS OF FACT
Many of the facts herein…
2Cases cited9 opinions
- Rothensies v. Electric Storage Battery Co.Supreme Court of the United States · 1946
- St. Louis Bank for Cooperatives v. United StatesUnited States Court of Claims · 1980
- Associated Milk Producers, Inc. v. CommissionerUnited States Tax Court · 1977
- Farm Service Cooperative v. CommissionerUnited States Tax Court · 1978
- Farm Service Cooperative v. Commissioner of Internal Revenue, National Council of Farmer Cooperatives, AmicusCourt of Appeals for the Eighth Circuit · 1980
4 more not listed; retrieve them via the Exa API.
3Cited by16 opinions
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- CF Indus., Inc. v. CommissionerUnited States Tax Court · 1991
- Washington-Oregon Shippers Cooperative, Inc. v. CommissionerUnited States Tax Court · 1987
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