Legal Opinion

Commissioner of Internal Revenue v. B. A. Carpenter

Court of Appeals for the Fifth Circuit

Decided March 2, 1955No. 15088_1PublishedCited by 30 opinions

1Opinion of the Court

HOLMES, Circuit Judge.

This appeal is from a decision of the Tax Court, which held that the respondent was not liable for alleged income tax deficiencies asserted to be owing for the fiscal years ending February, 1946, through 1949. The facts are not in dispute, and the only question is whether the respondent must include in his gross income the face amount of revolving fund certificates issued by a farmer cooperative association.

There was an agreement between Fos-gate Growers Cooperative, a farmer cooperative association, exempt under Section 101(12) of the Internal Revenue Code of 1939, 26…

2Cited by30 opinions

Union Equity Cooperative Exchange v. CommissionerUnited States Tax Court · 1972
Texas Trailercoach, Inc. v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1958
Long Poultry Farms, Incorporated v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1957
Anthony Theophilos Patricia A. Theophilos v. Commissioner Internal Revenue ServiceCourt of Appeals for the Ninth Circuit · 1996
Farmers Cooperative Company v. Commissioner of Internal RevenueCourt of Appeals for the Eighth Circuit · 1961

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