Mississippi Chemical Corp. v. Commissioner
United States Tax Court
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
Mississippi Chemical Corporation, Petitioner v. Commissioner of Internal Revenue, Respondent
Mississippi Chemical Corp. v. Commissioner
Docket Nos. 6556-82, 32440-831
United States Tax Court
86 T.C. 627; 1986 U.S. Tax Ct. LEXIS 128; 86 T.C. No. 39;
April 9, 1986, Filed
Decisions will be entered under Rule 155.
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…
2Cases cited18 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Commissioner v. HeiningerSupreme Court of the United States · 1943
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Siegel v. CommissionerUnited States Tax Court · 1982
- Lilly v. CommissionerSupreme Court of the United States · 1952
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