Legal Opinion

Associated Milk Producers, Inc. v. Commissioner

United States Tax Court

Decided August 25, 1977No. Docket No. 1493-75Published

1. For each of its taxable years 1959 through 1961, petitioner, a dairy cooperative, reported deductions in excess of gross income. Held: Petitioner entitled to net operating loss carryover deductions under sec. 172, I.R.C. 1954, in the succeeding years.

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1. For each of its taxable years 1959 through 1961, petitioner, a dairy cooperative, reported deductions in excess of gross income. Held: Petitioner entitled to net operating loss carryover deductions under sec. 172, I.R.C. 1954, in the succeeding years. Respondent's disallowance of net operating loss carryover, based upon "cost principle" of cooperative operation, rejected. 2. During each of its taxable years 1966 through 1968 petitioner made payments to reimburse operating deficits of a trust established to provide life insurance for member-patrons of petitioner. Held, under the…

1Opinion of the Court

Associated Milk Producers, Inc. (Successor to Rochester Dairy Cooperative), Petitioner v. Commissioner of Internal Revenue, Respondent

Associated Milk Producers, Inc. v. Commissioner

Docket No. 1493-75

United States Tax Court

68 T.C. 729; 1977 U.S. Tax Ct. LEXIS 65;

August 25, 1977, Filed

Decision will be entered under Rule 155.

1. For each of its taxable years 1959 through 1961, petitioner, a dairy cooperative, reported deductions in excess of gross income. Held: Petitioner entitled to net operating loss carryover deductions under sec. 172, I.R.C. 1954, in the succeeding years. Respondent's…

2Cases cited13 opinions

  1. Snow v. CommissionerUnited States Tax Court · 1958
  2. Dinardo v. CommissionerUnited States Tax Court · 1954
  3. L. Heller & Son, Inc. v. CommissionerUnited States Tax Court · 1949
  4. Catholic News Publishing Co. v. CommissionerUnited States Tax Court · 1948
  5. Pomeroy Coop. Grain Co. v. CommissionerUnited States Tax Court · 1958

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