Legal Opinion

Affiliated Foods, Inc., A Corporation v. Commissioner

United States Tax Court

Decided March 29, 2007No. 12846-04Unknown

1Opinion of the Court

128 T.C. No. 7

UNITED STATES TAX COURT AFFILIATED FOODS, INC., A CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 12846-04. Filed March 29, 2007. P, a wholesale food purchasing cooperative, holds one or more food shows a year at which member stores and vendors selling to P meet. The vendors offer special show discounts to member stores placing orders with P for the vendors’ products at the food shows. The special discount sometimes takes the form of a cash payment from the vendor to the member store based on the quantity of the vendor’s products ordered.…

2Cases cited28 opinions

  1. Parklane Hosiery Co. v. ShoreSupreme Court of the United States · 1979
  2. Montana v. United StatesSupreme Court of the United States · 1979
  3. Commissioner v. SunnenSupreme Court of the United States · 1948
  4. North American Oil Consolidated v. BurnetSupreme Court of the United States · 1932
  5. Commissioner v. WilcoxSupreme Court of the United States · 1946

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