Estate of Cordeiro v. Commissioner
United States Tax Court
Petitioners acquired a herd of dairy cows from a decedent, who was a member of a cooperative marketing association. Decedent was required to market all milk from the herd through the association. By virtue of his membership, decedent was allocated "base" by the association, which measured his share in the proceeds of the association's milk sales. Decedent's membership (and concomitant "right to base") lapsed upon his death.
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Petitioners acquired a herd of dairy cows from a decedent, who was a member of a cooperative marketing association. Decedent was required to market all milk from the herd through the association. By virtue of his membership, decedent was allocated "base" by the association, which measured his share in the proceeds of the association's milk sales. Decedent's membership (and concomitant "right to base") lapsed upon his death. The association permitted petitioners to succeed to decedent's membership, and subsequently decedent's wife, a petitioner herein, became a member of the association. Held,…
1Opinion of the Court
Tannenwadd, Judge:
Respondent originally determined deficiencies in income tax and by timely amendment to answer increased those deficiencies, as follows:
Petitioners Period Original Revised deficiency deficiency
Estate oí Tony Cordeiro, deceased (docket No. 3755-66)-Sept. 5, through $1,529.84 $3,678.17
Dec. 31,1961.
Estate of Tony Cordeiro, deceased, and Mary Cordeiro 1959. 16,671.61 18,197.16
(docket No. 3757-66). 1961. 11,036.29 12,571.51
The issues remaining for decision (depreciation and loss on sale and death of cows) all turn upon the value of a herd of dairy cows at the time of Tony…
2Cases cited4 opinions
- Helvering v. TaylorSupreme Court of the United States · 1935
- Farber v. CommissionerUnited States Tax Court · 1965
- Delone v. CommissionerUnited States Tax Court · 1946
- Vander Hoek v. CommissionerUnited States Tax Court · 1968
3Cited by16 opinions
- Estate of Mandels v. CommissionerUnited States Tax Court · 1975
- Goodman v. CommissionerUnited States Tax Court · 1980
- Van De Steeg v. CommissionerUnited States Tax Court · 1973
- Vander Hoek v. CommissionerUnited States Tax Court · 1968
- Sorrell v. CommissionerUnited States Tax Court · 1987
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