Legal Opinion

Fruit Growers Supply Co. v. Commissioner

United States Board of Tax Appeals

Decided November 13, 1930No. Docket No. 30333Published

1. A corporation which acts as purchasing agent for the purpose of purchasing supplies for the members of a cooperative association at cost, but at the same time carries on a substantial amount of business with nonmembers at a profit, is not exempt from taxation under the provisions of section 231(11) of the Revenue Act of 1921. 2. Where a corporation of the character referred to above pays patronage dividends to its members on the basis of purchases made for such members,…

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1. A corporation which acts as purchasing agent for the purpose of purchasing supplies for the members of a cooperative association at cost, but at the same time carries on a substantial amount of business with nonmembers at a profit, is not exempt from taxation under the provisions of section 231(11) of the Revenue Act of 1921. 2. Where a corporation of the character referred to above pays patronage dividends to its members on the basis of purchases made for such members, such dividends which are paid out of profits from nonmember business may not be considered a reduction of the cost of the…

1Opinion of the Court

FRUIT GROWERS SUPPLY CO., PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

Fruit Growers Supply Co. v. Commissioner

Docket No. 30333.

United States Board of Tax Appeals

21 B.T.A. 315; 1930 BTA LEXIS 1868;

November 13, 1930, Promulgated

1. A corporation which acts as purchasing agent for the purpose of purchasing supplies for the members of a cooperative association at cost, but at the same time carries on a substantial amount of business with nonmembers at a profit, is not exempt from taxation under the provisions of section 231(11) of the Revenue Act of 1921.

2. Where a corporation of…

2Cases cited9 opinions

  1. Trinidad v. Sagrada Orden De Predicadores De La Provincia Del Santisimo Rosario De FilipinasSupreme Court of the United States · 1924
  2. Fruit Growers Supply Co. v. CommissionerUnited States Board of Tax Appeals · 1930
  3. Farmers' Union Co-Op. Ass'n v. CommissionerUnited States Board of Tax Appeals · 1928
  4. Trego County Cooperative Asso. v. CommissionerUnited States Board of Tax Appeals · 1927
  5. Appeal of Waynesboro Manufacturers Ass'nUnited States Board of Tax Appeals · 1925

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